Skip to main content

Full text of "Joint environmental impact statement and environmental impact report : proposed agreement between the United States of America and the Department of Water Resources of the state of California for coordinated operation of the Central Valley Project and the State Water Project"

See other formats


F 




'A 




Environmental Impact Statement/Report 
Coordinated Operation Agreement 

Central Valley Project/State Water Project 



120.01 

R299 

13878 


Donald Model David Houston 


1986 
c. 2 


Secretary of Interior Regional Director 
Department of Interior Mid-Pacific Region 

Bureau of Reclamation 


MP 


Jon K. Van VIeck George Deukmejian David N. Kennedy 


Secre 
The R 


tary foT Resources Governor Director 

esourcefe Agency State of California Department of Water Resources 



DATE DUE 




IOQI 






^Bl^ 


n3» 























































































LIBRARY- MP REGION 

U.S. Bureau of Reclamation 

2800 Cottage Way 
Sacramento, CA 958251898 



aa BURii^AU OF RECLAMATi'-p 
2300 COITAGE WAY 






JOINT ENVIRONMENTAL IMPACT STATEMENT 
AND ENVIRONMENTAL IMPACT REPORT 



PROPOSED AGREEMENT BETWEEN THE 

UNITED STATES OF AMERICA 

AND THE 

DEPARTMENT OF WATER RESOURCES OF THE 

STATE OF CALIFORNIA 

FOR COORDINATED OPERATION OF THE 
CENTRAL VALLEY PROJECT 
AND THE 
STATE WATER PROJECT 



April 1986 





Donald Hodel 
Secretary of Interior 
Department of Interior 



David Houston 
Regional Director 
Mid-Pacific Region 
Bureau of Reclamation 



Gordon K. Van Vleck. 
Secretary for Resources 
The Resources Agency 



George Deukmejian 

Governor 

State of California 



David N. Kennedy 
Director 
Department of 
Water Resources 



JOINT ENVIRONMENTAL IMPACT STATEMENT 
AND ENVIRONMENTAL IMPACT REPORT 

PROPOSED AGREEMENT BETWEEN THE 
UNITED STATES OF AMERICA 
AND THE 
DEPARTMENT OF WATER RESOURCES OF THE 
STATE OF CALIFORNIA 

FOR COORDINATED OPERATION OF THE 
CENTRAL VALLEY PROJECT 
AND THE 
STATE WATER PROJECT 



Responsible Agencies 

U. S. Department of Interior 

Bureau of Reclamation and 

California Department of Water Resources 



Status: FINAL ^ « 

iFES 56 - lo 

Statement number: > '__ 

JUL? 19d& 



Filing date: 



Abstract: The Proposed Action of signing and implementing the draft Coordinated 
Operation Agreement obligates both the Central Valley Project and the 
State Water Project to meet water quality and outflow standards extracted 
from the State Water Resources Control Board Decision 1485 designed for 
protecting the beneficial uses of the Sacramento-San Joaquin Delta water 
supply. Without this Agreement (No Action), the Central Valley Project's 
participation in meeting these standards wDuld not be assured in 
critically dry years. As compared to No Action, the Proposed Action 
would have beneficial environmental impacts in the Delta and could have 
adverse impacts on salmon spawning and rearing in the upper Sacramento 
and Trinity rivers, depending on how the two water projects wauld be 
operated in No Action. 



For Further Information Contact 

Bob Schroeder Karl Winkler 

Bureau of Reclamation California Department of Water 

2800 Cottage Way, Room W-2137 or Resources 

Sacramento, CA 95825 3251 S Street, Room D-4 

Phone: (916) 978-4923 Sacramento, CA 95816 

Phone: (916) 445-5955 



I 
J 

! 

I 
I 
1 

I 
II 
H 



u 
I 
I 
I 

It 

n 



Bimm msm 



CONTENTS 

Page 

COORDINATION FOR REVIEW OF THE DRAFT AND FINAL 

ENVIRONMENTAL STATEMENT/ENVIRONMENTAL IMPACT REPORT v 

INTRODUCTION 1 

Public Involvement 2 

Table 1. Comments and Issues 4 

Section 1. GENERAL ISSUES 7 

Alternatives 7 

Reauthorization 8 

Decision 1485 Standards 9 

Future Standards/Termination Provisions 14 

Future Water Marketing 16 

Salmon 17 

Striped Bass Decline 19 

Suisun Marsh 21 

San Francisco Bay 22 

Wetlands and Habitat in the Central Valley 25 

Area of Origin 27 

Seepage 27 

Southern Delta 29 

Recreation 30 

Levees and Cross-Delta Flows 31 

Friant and New Melones Projects 32 



Hi 



Page 

Section 2. CORRECTIONS AND ADDITIONS 35 

CVP/SWP Coordinated Operation Agreement, California, 

A Detailed Report on Fish and Wildlife Resources .... 43 

Response by Bureau of Reclamation 78 

Section 3. C(M4ENT LETTERS AND TRANSCRIPT OF PUBLIC MEETINGS ... 89 

Section 4. DRAFT EIR/EIS 147 



Iv 



COORDINATION FOR REVIEW OF THE DRAFT AND FINAL 
ENVIRONMENTAL STATEMENT/ENVIRONMENTAL IMPACT REPORT 

The draft and this final environmental document have been distributed to all agencies, 
organizations, and individuals who have expressed an interest in the COA. Those 
indicated by an asterisk (*) provided written comments on the draft. 

Federal Agencies 

Copies were distributed to the following by the Commissioner, Bureau of Reclamation for 
review and comment. 

U. S. Department of the Interior 

Bureau of Indian Affairs 

Bureau of Land Management 

Bureau of Mines 

*Fish and Wildlife Service 

Geological Survey 

^National Park Service 

Western Region Office - Secretary of the Interior 

Other Federal Agencies 

Advisory Council on Historic Preservation 
Council on Environmental Quality 
Department of Agriculture 
Department of the Army 
Department of Commerce 
Department of Energy 

Bonneville Power Administration 

Federal Energy Regulatory Commission 
Department of Health and Human Services 
Department of Housing and Urban Development 
Department of Transportation 
^Environmental Protection Agency 



i ^ 



. S. Senate 



Alan Cranston and Pete Wilson 

U. S. Congress 

Douglas H. Boscow; Anthony C. Beilenson; Eugene A. Chappie; Henry A. Waxman; Robert T. 
Matsui; Edward R. Roybal; Vic Fazio; Howard L. Berman; Sala Burton; Mel Levine; Barbara 
Boxer; Julian C. Dixon; *George Miller; Augustus F. (Gus) Hawkins; Ronald V. Dellums; 
Matthew G. Martinez; Fortney H. (Pete) Stark; Mervyn M. Dymally; Don Edwards; Glenn M. 
Anderson; Tom Lantos; David Dreier; Edwin V. W. Zschau; Esteban E. Torres; Norman Y, 
Mineta; Jerry Lewis; Norman D. Shumway; George E. Brown, Jr.; Tony Goelho; Alfred A. 
McCandless; Leon E. Panetta; Jerry M. Patterson; Charles Pashayan, Jr. ; William E. 
Dannemeyer; Richard H. Lehman; Robert E. Badham; Robert J. Lagomarsino; Bill Lowery; 
William M. Thomas; Dan E. Lungre; Bobbi Fiedler; Ronald C. Packard; Carlos J. Moorhead; 
Jim Bates; and Duncan L. Hunter. 



Federal Agencies 

Copies were distributed to the following by the Regional Director, Bureau of 
Reclamation, for information only. 

Department of the Interior 

Regional Environmental Officer, San Francisco, California 

Bureau of Indian Affairs, Sacramento, California 

*Fish and Wildlife Service, Portland, Oregon, and Sacramento, California 

*National Park Service, San Francisco, California 

Geological Survey, Menlo Park, California 

Bureau of Land Management, Sacramento, California 

Bureau of Mines, Spokane, Washington 

Other Federal Agencies 

Department of Agriculture 

Forest Service, San Francisco, California 

Soil Conservation Service, Davis, California 
Department of the Army, Corps of Engineers, San Francisco and Sacramento, California 
Department of Health and Human Services, San Francisco, California 
Department of Energy, WAPA, Sacramento, California 
Department of Transportation, Highway Administration, San Francisco, California 

State and Local Agencies 

Copies were distributed to the following by the Regional Director, Bureau of 
Reclamation, for review and comment. 

California State Senate 

Ray Johnson; Dan McCorquodale; Barry Keene, Henry J. Mello; John Doolittle; Leroy F. 
Greene; James W. Nielsen; Wadie P. Deddeh; Milton Marks; Herschel Rosenthal; John 
Francis Foran; Edward R. Royce; Ed Davis; Alan Robbins; Jim Ellis; Newton R. Russel; 
Nicholas C. Petris; John Seymour; Daniel E. Boatwright; David A. Roberti; Alfred E. 
Alquist; Art Torres; Ollie Speraw; H. L. Richardson; John R. Garamendi; Joseph B. 
Montoya; Rose Ann Vuich; Robert C. Beverly; Walter W. Stiern; Ralph C. Dills; Gary 
Hart; Bill Greene; Bill Lockyer; Diane Edith Watson; Ken Maddy; Ruben S. Ayala; Paul B. 
Carpenter; William (Bill) Campbell; William A. Craven; and Robert Presley. 

California State Assembly 

Stan Statham; Tom Bane; Doris Allen; Patrick J. Nolan; Rusty Areias; Bill Jones; 
Thomas M. Hannigan; Richard Katz; Jean M. Duffy; Lucy Killea; Norman Waters; Johan 
Klehs; Charles W. Bader; Mike Rooce; William J. Filante; Teresa Hughes; Byron D. Sher; 
Maxine Waters; William P. Baker; Gwen Moore; William R. Bradley; Curtis R. Tucker; Tom 
Bates; Ernest L. Konnyu, Elihu M. Harris; Gerald N. Felando; Bruce Bronzan; Marian 
LaFollerte; Charles M. Calderon; Frank Vicencis; Art Agnos; Richard Alatorre; Willie L. 
Brown; John R. Lewis; Robert J. Campbell; Dave Elder; Louis J. Papan; Dennis L. Brown; 
Robert W. Naylor; Burt M. Margolin; Steven Clute; Sally Tanner; Tom Hayden; Richard 
Mountjoy; John Vasconcellos ; Bill Lancaster; Gary Condit; Alister McAlister; Tom McClintocl 
Lloyd C. Connelly; Dominic Cortese; William R. Leonard; Gray Davis; Sunny Mojonnier; 
Sam Farr; Ross Johnson; Jim Costa; Gloria Molina; Richard E. Floyd; Jack O'Connell; 
Nolan Frizzelle; Richard Robinson; Don Rogers; Steve Peace; Phillip D. Wyman; Dan 
Hauser; David G. Kelley; Wally Herger; Robert C. Frazee; Frank Hill; Eric Seastrand; 
Philip Isenberg; Don A. Sebastiani; Patrick Johnson; Peter R. Chacon; and Cathie Wright. 

vi 



State Agencies 

California State Clearinghouse, Office of the Governor, Sacramento (including 
*Department of Fish and Game and *State Water Resources Control Board) 

Local Agencies 

*South Delta Water Agency 

San Joaquin County Flood Control and Water Conservation District 

*Alameda County Water District 

Hospital Water District 

Westlands Water District 

Arvin-Edison Water Storage District 

Kern County Water Agency 

Tulare Irrigation District 

Terra Bella Irrigation District 

Berrenda Mesa Water District 

Rag Gulch Water District 

Glenn-Colusa Irrigation District 

Orland-Artios 

Westside Water District 

Shasta County Water Agency 

Metropolitan Water District of Southern California 

Anderson-Cottonwood Irrigation District 

Shasta Dam Area Public Utility District, City of Redding 

Bella Vista Water District 

Clear Creek Community Services District 

City of Antioch 

*Contra Costa Water Agency 

East Bay Municipal Utility District 

Suisun Resource Conservation District 

Tulare Lake Basin and Irrigation District 

Central Delta Water Agency 

Lower Tule River Irrigation District 

Orange County 

Contra Costa Water District 

*Santa Clara Valley Water District 

Rosedale-Rio Bravo Water Storage District 

East Contra Costa Irrigation District 

Reclamation District 2060 

Casitas Municipal Water District 

Association of California Water Agencies 

San Gabriel Valley Municipal Water District 

Yuba County Water District 

Reclamation District 2064 

Banta-Carbona Irrigation District 

Kings County Planning Agency 

Mojave Water Agency 

Sonoma County Library 

San Bernardino County Library 

Butte County 



vii 



Glenn County Planning Department 

Solano County Public Works 

Kern County Planning 

Provident Irrigation District 

Kanawha Water District 

Calaveras County Planning Department 

Plumas County Flood Control and Water Conservation District 

*San Juan Suburban Water District 

Tulare County Board of Supervisors 

Desert Water Agency 

San Gorgonio Pass Water Agency 

Keswick Community Services District 

Yolo County Flood Control and Water Conservation District 

Kings County Water District 

San Luis Canal County 

San Benito County Water Conservation and Flood Control District 

Madera Irrigation District 

Coachella Valley Water District 

Saucelito Irrigation District 

Princeton-Codora-Glenn Irrigation District 

Central San Joaquin Water Conservation District 

Sacramento Municipal Utility District 

Glenn County Board of Supervisors 

Northridge Water District 

County of Tuolumne Board of Supervisors 

Modesto Irrigation District 

Monterey County Flood Control and Water Conservation District 

Glide Water District 

*Yolo-Zamora Water District 

Trinity Recreational Association 

Dunnigan Water District 

Placer County Board of Supervisors 

*Colusa County Water District 

Centerville C.S.D. 

Reclamation District 108 

El Dorado County Water Agency 

City of Folsom 

El Dorado Irrigation District 

Grassland Water District 

Shaf ter-Wasco Irrigation District 

City of Coalinga 

Devil's Den Water District 

Green Valley Water District 

^Trinity County 

Foresthill Public Utility District 

Thomas Creek WAter District 

Antelope Valley East Kern Water Agency 

Sacramento County Water Agency 

Palm Springs Public Library 

Bethel Island Municipal Improvement District 

Brannan-Andrus Levee Maintenance District 

Contra Costa 

Broadview Water District 

Fresno County Farm Bureau 

Castaic Lake Water Agency 



viii 



city of Redding 

*Sacramento Valley Westside Canal Association 

*Central Valley Project Water Association 

*Northern California Power Agency 

*North Delta Water Agency 

Central California Irrigation District 

Pacheco Water District 

Palmdale Water District 

Orange Cove Irrigation District 

Corcoran Irrigation District 

Chowchilla Water District 

San Bernardino Valley Municipal Water District 

Dudley Ridge Water District 

Alpaugh Irrigation District 

Delano-Earl imart Irrigation District 

Wasco Semitropic Water Storage District 

Westley Hospital Water District 

Alameda County Flood Control and Water Conservation District 

Orland-Artois Water District 

City of Rio Vista 

State Water Contractors Audit Committee 

Sacramento County Environmental Section 

San Joaquin County 

San Bernardino County 

James Irrigation District 

Mercy Springs Water District 

City of Watsonville 

Union Island Reclamation District 2 

Organizations 

*Bay Institute of San Francisco 

State Water Contractors 

J. B. Summers CE, Inc. 

CH2M Hill 

Montgomery Engineers 

Environmental Defense Fund 

Marin Conservation League 

United Anglers of California 

California Wildlife Federation 

Save San Francisco Bay Association 

California Academy of Sciences 

Buena Vista Audubon Society 

Cooperative Extension, University of California, Science and Industry Department 

Western Water Education Foundation 

Pacific Rod and Gun Club 

Burris, Lagerlof, Swift, and Senecal , Oceanic Society 

Sierra Club 

River Garden Farms Co. 

Minasian, Minasian, Minasian, Spruance , Baber , Meith and Soares, Attorneys at Law 

Friends of the Earth 

Friant Water Users Association 

California Water Resources Association 

Klamath-Trinity River Coalition, Inc. 

Friends of the River 



ix 



Newhall Land and Farming Co. 

*Natural Resources Defense Council 

Redding Chamber of Commerce 

Pacific Gas and Electric Company 

Murray, Burns and Kienlen 

♦California Waterfowl Association 

*Lak.e Shasta Caverns 

California Fly Fishermen Unlimited 

Delta Water Users Association 

Sequoia Audubon Society 

San Joaquin River Water Users Company 

California Striped Bass Association 

Bookman-Edmonston Engineering, Inc. 

TERA Corporation 

Stockton Sportsmen Club 

R. L. Mitchel Associates 

Lag una Hills Audubon 

Delta Environmental Advisory Committee 

Resource Management Associates 

San Felipe Committee 

♦Committee for Water Policy Concensus 

♦Defenders of Wildlife 

♦Sacramento River Preservation Trust 

♦California Trout 

Marine Research Center 

San Jose Sport smens Club 

National Water Resources Association 

R. L. Schafer and Associates, Inc. 

Stetson Engineers, Inc. 

Salmon Unlimited 

Leedshill-Herkenhof f , Inc. 

Sacramento League of Women Voters 

♦National Audubon Society 

Individuals 

Mike Geranio; Harry S. Dixon; Francis H. Saunders; Allan Thode; John L. Winther; 
Parker M. Holt; Ernest A. Engelburt; Michael Smith; Fredrick Bold, Jr.; Mary C. Jacks; 
Merrill R. Goodall; F. B. Young; lila N. Collin; William E. Warne; Yosh Hamatani; Lee 
Walton; R. V. Thomas; D. W. Kelly; Tom Kearcher; Harold A. Keelen, Jr.; James E. 
Cummuns; Dean Thompson; Leroy Dutra; Richard M. Boswell; Samuel E. Wood; Richard Sitts; 
Col. R. Dana Fish; Pete Ratto, Sr.; Eunice Hunt; Ronald Robie; Paul E. Minor; Edgar 
Wilson; Ken G. Murray; Albert A. Amaro; Wes Anderson; Stacy Lee; Walter C. Sniz; Araalio 
Gomez; Vernon Bengal; Galen Whitney; Robert Pafford; Chet Sarsfield; R. W. Hollis; 
Kelly Nimtz; Alfred R. Golze; Robert E. Thorsen; Michael Simpson; L. K. Oonlin; Edward 
Taylor; Dorothy Green; Wayne Waters; Marshall Jones 

Media 

Stockton Record 

Record Searchlight 

Oakland Tribune 

San Francisco Chronicle 

Capital Tipster Newsletter 

Tracy Press 



INTRODUCTION 



The alternative preferred by the 
Department of Water Resources and the 
U. S. Bureau of Reclamation is signing 
and implementing the draft Coordinated 
Operation Agreement of May 20, 1985 as 
presented in Appendix A of the Draft 
Environmental Impact Statement/Report. 
This agreement obligates both the 
Federal Central Valley Project and the 
State Water Project to meet water qual- 
ity and outflow standards taken from 
State Water Resources Control Board 
Decision 1485 for protecting beneficial 
uses of the Sacramento-San Joaquin 
Delta water supply. This agreement is 
designed to increase the efficient use 
of existing water supplies by defining a 
sharing process for the State Water 
Project and the Central Valley Project 
to meet in-basin use and exports. 



After careful ev 
received on the 
Impact Statement 
determined that 
would be caused 
Coordinated Oper 
therefore no mit 
Also, many of th 
and individuals 
of the Coordinat 



aluation of all comments 
Draft Environmental 
/Report, it was 
no significant impacts 
by implementation of the 
at ion Agreement, and 
igation is recommended, 
e commenting agencies 
favored implementation 
ed Operation Agreement. 



The essence of the agreement is the 
sharing formula, which provides for a 
Central Valley Project/State Water 
Project proportionate split of 75/25 
responsibility for meeting in-basin use 
from stored water releases and 55/45 for 
the capture and export of excess flow. 
Both parties also agree to meet a 
specified set of Delta water quality 
standards (Exhibit A of the May 20, 
1985, Agreement) from State Water 
Resources Control Board Decision 1485. 
Exhibit A standards are a set of water 
quality standards and export and flow 
restrictions that define the Delta 
portion of in-basin use requirements. 



These standards provide more environmen- 
tal protection than the Bureau's present 
water quality requirements, known as 
"Tracy standards", by adding about 100 
new protective criteria at 15 additional 
Delta locations. This agreement also 
requires a commitment of about 2.3 mil- 
lion acre-feet from both projects during 
a critical water supply period to meet 
Delta flow and quality protective needs. 

The Final Environmental Impact 
Statement/Report is in four sections. 
Section 1 contains discussions of 16 
general issues that represent and 
respond to comments on the Draft 
Environmental Impact Statement/Report. 
These issues represent subjects 
requiring more clarification. 

Section 2 presents actual corrections 
and additions to the Draft Environmental 
Impact Statement/Report based on com- 
ments received during the public review 
period. This section provides informa- 
tion on comments requiring more specific 
detail than provided in Section 1, in- 
cluding new wording for changes to the 
text of the draft report. 

Section 3 contains copies of all letters 
received on the draft report and copies 
of transcripts of both public meetings. 
This section shows questions and various 
points of view of agencies and indivi- 
duals \k\o commented on the draft report. 

The Draft Environmental Impact 
Statement/Report is included as 
Section 4. 

The information contained in this docu- 
ment, which also incorporates the Draft 
Environmental Impact Statement/Report, 
fulfills both the Federal and State 
environmental guidelines for the content 
of a Final Environmental Impact 
Statement/Report . 



Public Involvement 

Guidelines of the National Environmental 
Policy Act (NEPA) and the California 
Environmental Quality Act (CEQA) require 
that the sponsoring or lead agency 
respond in writing to all comments 
received during public review of a draft 
environmental impact statement report. 
The responses to these comments, the 
draft environmental impact statement/ 
report, and revisions to the draft re- 
port constitute the final environmental 
impact statement/report. 

Public participation has been important 
in developing the Coordinated Operation 
Agreement Environmental Impact 
Statement/Report. Early and regular 
consultation with responsible agencies 
and the public was instrumental in 
preparing the Draft Environmental Impact 
Statement/Report (see Appendix C of the 
draft report). 

About 700 copies of the draft report 
were initially distributed for public 
and agency review; subsequently about 
300 additional copies were distributed 
upon request. Notices were placed in 
major newspapers throughout the State 
notifing the public of meetings and the 
availability of the draft report. 

Issuance of the draft report on 
September 13, 1985, initiated a 60-day 
public and agency review period, ending 
November 13, 1985. During this period, 
two public meetings were held to receive 
comments on the draft report: one on 
October 22 in Sacramento and one on 
November 7 in Concord, California. 
Twelve speakers provided oral comments 
at the two meetings. During the review 
period, 34 letters were received, 
providing comments on the draft report. 
These commenting entities are listed 
below: National Audubon Society 
(Audubon), Lake Shasta Caverns, 
California Waterfowl Association, 
Committee for Water Policy Consensus 
(Cora Water Pol Con), Defenders of 
Wildlife, The Bay Institute of San 
Francisco, Natural Resources Defense 



Council, Inc. (NRDC) , Sacramento River 
Preservation Trust, California Trout, 
Inc., Yolo-Zamora Water District, 
Sacramento Valley Wests ide Canal 
Association, San Juan Suburban Water 
District, South Delta Water Agency, 
Colusa County Water District, Santa 
Clara Valley Water District, Central 
Valley Project Water Association 
(CVPWA), North Delta Water Agency, 
Central California Valleys Flood Control 
Association (CCVFCA), Contra Costa 
County Water Agency (CCC WA) , Northern 
California Power Agency, Trinity County, 
Alameda County Water District, 
Department of Fish and Game (DFG) , 
Native American Heritage Commission 
(Nat Am Hert Com), State Water 
Resources Control Board (SWRCB) , Office 
of Planning and Research (OPR) , 
Environmental Protection Agency (EPA), 
Bureau of Land Management (BLM), Corps 
of Engineers (COE), National Park 
Service and the U. S. Fish and Wildlife 
Service . 

Oral presentations were given by the 
following: Richard Spotts, Gerald 
Schumacher, Norman Sturm, John Lawrence, 
Lori Griggs, John Divito, Laura King, 
William Davoren, David Okita, Tom Graff, 
Frederick Bold, and Tom Torlakson. 

This was a complex and somewhat unique 
project, touching on many significant 
and sensitive issues. Many comments 
raised issues that, although related to 
project operations, were beyond the 
scope and intent of the Coordinated 
Operation Agreement, and were generally 
related to separate or future actions 
not governed by the Agreement . Even 
though these are separate issues, they 
are important to clarify, and the 
general issues section provides 
discussion on these points. 

Responses to comments received are 
presented in two ways. First, because a 
number of the comments touched on the 
same issues, these comments were grouped 
into general issues, and a single, 
expanded response to each of these major 
issues was provided. Second, connraents 



that did not fall within the scope of 
one or more of the general issues or 
that required changes to the text were 
dealt with specifically in Section 2, 
Corrections and Additions. 

Table 1 presents a matrix listing of all 
those v*io provided comments, a list of 
the 16 general issues, and an indication 
of how each letter or oral comment was 
treated. 



Review of general issues found important 
subjects requiring more discussion for 
clarification; however, no significant 
impacts attributable to implementing the 
Coordinated Operation Agreement were 
identified after review of all issues. 
It should also be noted that the issue 
descriptions in the general issue sec- 
tion represent views of commentors, and 
do not necessarily reflect views of the 
Department of Water Resources or the 
Bureau of Reclamation. 







Table 1 
















COMCNTS 


AND ISSUES 














Altema- Reauth- 


Decision 


ruture 


Water 




Striped 


Suisun 


San Frar 




tives orization 


1485 


Stwdards 


Marketing 


Salaon 


Bass 


Marsh 


Cisco Bi 


Letters Received 


















Audibon 




X 




X 


X . 








Lake Shasta Caverns 


















Calif Waterfowl Assoc 


X 






X 






X 




Com Water Pol Consensus 


X 


X 


X 




X 


X 


X 


X 


Oef Wildlife 


X X 






X 










Bay Inst SF 




X 




X 




X 






NRDC 


X 


X 


X 


X 


X 








Sac to River Pres Trust 


X 




X 




X 








California Trout 


X 






X 


X 






X 


Yolo-Zanora WD 








X 










Sac Val West Canal Assoc 








X 










San Juan WD 








X 










South Delta WA 




X 




X 










Colusa Cointy WD 


















Santa Clara WD 


















CVP Water Association 








X 










hbrth Delta WA/CCVFCA 


















CCC WA 




X 


X 


X 


X 


X 


X 


X 


Nbrth Calif Power 


















Trinity County 










X 








Alameda County WD 


















DFG (11-13) 








X 


X 






X 


DFG (10-29) 


















Nat ka Hert Com 


















SWRCB 




X 


X 


X 




X 


X 


X 


OPR 


















EPA 


X 


X 


X 


X 






X 


X 


BLM 


















COE 


















National Park Service 


















Fish and Wildlife Service 


X 


X 




X 


X 


X 




X 


Oral Presentation at Public Meetings 
















Richard Spotts 


X 






X 


X 








Gerald Schumacher 


















Norman Sturm 


















John Lawrence 


















Lori Griggs 




X 


X 






X 




X 


Jbhn Divito 


X 


X 














Laura King 




X 


X 


X 


X 








William Davoren 




X 








X 






David Okita 




X 








X 






Tom Graff 




X 


X 


X 




X 




X 


Frederick Bold 






X 












Tom Torlakson 




X 


X 


X 




X 


X 


X 









Table 1 (Continued) 
















COHMENTS AND ISSUES 


Levees/ 






Changes 




Wetlands/ 


Area of 


Southern Recrea- 


X-Oelta 


Frisnt 


Support 


to Draft 




Habitat 


Origin 


Seepaqe Delta tion 


FIOMS 


New Helones 


of COA 


EIS/R 


Letters Received 
















Audubon 


X 










X 


X 


Lake Shasta Caverns 






X 










Calif Waterfowl Assoc 


X 














Com Water Pol Consensus 


X 




X 




X 


X 


X 


Def Wildlife 


X 










X 




Bay Inst SF 


X 












X 


NRDC 


X 










X 




Sacto River Pres Trust 


X 










X 




California Trout 


X 








X 




X 


Yolo-Zamora WD 




X 










X 


Sac Val West Canal Assoc 




X 










X 


San JUan WD 














X 


South Delta WA 






X 








X 


Colusa County WD 




X 










X 


Santa Clara WD 














X 


CVP Water Association 














X 


North Delta WA/CCVFCA 






X 


X 






X 


CCC WA 










X 


X 


X 


North Calif Power 










X 




X 


Trinity County 


X 




X 










Alameda County WO 












X 




DFG (11-13) 


X 




X 








X 


DFG (10-29) 












X 




Nat Am Hert Com 
















SWRCB 




X 




X 






X 


OPR 
















EPA 












X 




BLM 
















COE 
















National Park Service 














X 


Fish and Wildlife Service 


X 




X 


X 






X 


Oral Presentation at Public Meetinqs 










X 




Richard Spotts 


X 




Gerald Schumacher 












X 




Norman Sturm 
















John Lawrence 












X 




Lori Griggs 










X 


X 




John Divito 
















Laura King 


X 














William Davoren 


X 














David Okita 










X 






Tom Graff 


X 














Frederick Bold 
















Tom Torlakson 






X 






X 





Section 1, 



GENERAL ISSUES 



Review of written and oral comments on 
the Draft Environmental Impact Report/ 
Statement showed the majority of these 
comments could be grouped into 16 gen- 
eral issues. An issue statement was 
developed for each general issue based 
on the actual comments received. The 
issue statements do not necessarily 
reflect the position of the Department 
of Water Resources or the Bureau of 
Reclamation on the issue. A response 
provided for each issue discusses the 
relationship to the Coordinated Opera- 
tion Agreement and the Environmental 
Impact Report/ Statement . 

Comments requiring more specific detail 
or changes to the text of the draft 
report are presented in Section 2, 
Corrections and Additions. 



Alternatives 



Issue 



The Coordinated Operation Agreement 
Draft Environmental Impact Statement/ 
Report did not evaluate a reasonable 
array of alternatives, nor did it 
evaluate an optimum fish and wildlife 
protection alternative or worst-case 
scenario alternative. 



Response 

The Department and the Bureau recognize 
the requirement to evaluate a reasonable 
array of alternatives. The alternatives 
evaluated in the draft report were a 
reasonable array and included both an 
optimum fish and wildlife protection 
alternative and a worst-case scenario 
alternative . 

Table S-1 summarized the six alterna- 
tives included in the draft report and 



presented advantages and disadvantages 
of each. To optimize fish and wildlife 
concerns, two alternatives were 
considered. One is the preferred 
alternative, which includes adding about 
100 separate water quality and flow 
protection criteria for the Delta 
environment. This alternative requires 
a commitment of about 2.3 million 
acre-feet of project critical period 
firm yield for environmental protection. 
Provisions to incorporate Suisun Marsh 
protective standards into the agreement 
are also included in the preferred 
alternative. Negotiations on a Suisun 
Marsh Preservation Agreement were 
concluded successfully in August 1985. 
Parties to the Marsh agreement include 
the Department of Water Resources, 
Department of Fish and Game, Bureau of 
Reclamation, and Suisun Resource 
Conservation District. 

A modified agreement alternative, also 
included in the draft report, provided 
another option for fish and wildlife 
protection. This alternative included 
expanding the scope of the agreement 
using a draft article proposed by the 
U. S. Fish and Wildlife Service and 
presented at a negotiating session on 
July 14, 1982. This provision, which 
includes goals of fishery restoration 
and enhancement , was considered for some 
time by the negotiators but was not 
adopted. It was discussed on page 25 of 
the draft report, but was not included 
in the detailed analysis used for the 
preferred alternative. 

Even though the article proposed by 
the Fish and Wildlife Service was not 
adopted, its idea of taking more action 
to protect fish and wildlife is included 
in State and Federal water resource 
planning that is separate from this 
Agreement. Examples include: 



° Suisun Marsh protective planning. 

" Use of $5 million of State Water 
Project funds to improve the John E. 
Skinner Delta Fish Protective 
Facility. 

Negotiations between the Department of 
Water Resources and Department of Fish 
and Game to use several million dol- 
lars of State Water Project funds for 
additional fish protective measures 
to compensate for fish that would have 
been in the Delta if Banks Pumping 
Plant had not been constructed. 

Funding of interagency ecological 
studies that are identifying fish and 
wildlife needs in the Delta and San 
Francisco Bay; more than $20 million 
has been contributed by the State 
Water Project and more than $10 mil- 
lion by the Central Valley Project. 

Continued operation and improvement 
of fish hatcheries on the American, 
Feather, and Sacramento rivers. 

" The Central Valley Fish and Wildlife 
Management Study to investigate water 
supply needs for Federal and State 
wildlife refuges in the Central 
Valley. The interagency team is now 
completing an appraisal-level study to 
identify problems and needs of the 
refuges. A 2-year planning study 
began in fiscal year 1986 to identify 
sources of water and the best plan for 
the refuges. 

More discussion on measures for fish and 
wildlife protection in addition to the 
proposed agreement is included in the 
general issue on Decision 1485 
standards . 

Improved protection for fish and wild- 
life will be an objective for future 
Delta standards, and the Coordinated 
Operation Agreement has provisions for 
including future standards if adopted. 
Implementing the preferred alternative 
does not preclude adoption of standards 
that may broaden the scope of the 



proposed agreement, nor does it preclude 
separate actions or agreements regarding 
water supply allocations to meet fish 
and wildlife needs in the Central 
Valley. 

Analysis of the worst-case scenario 
demonstrated the potential temperature- 
related impacts to salmon upstream of 
the Delta (see pages 75 to 81 of the 
draft report) . Operation studies used 
for the analysis included an assumption 
that maximized environmental differences 
between alternatives — that the water 
both projects could save by meeting 
Tracy standards (no project) rather than 
Exhibit A standards (proposed action) 
would be retained in the reservoirs 
during critical years. This is not the 
most likely type of project operations, 
but it does represent a vrorst-case 
comparison. Implementation of the 
preferred alternative, even in light of 
this worst-case analysis, was judged not 
to have significant impacts and to pro- 
vide improved environmental protection 
for the Delta, For more information on 
this worst-case analysis, see the 
general issue on salmon. 



Reauthorization 



Issue 



The Coordinated Operation Agreement in 
effect reauthorizes the Central Valley 
Project, thus making water quality an 
authorized purpose of the project. This 
reauthorization should commit the Bureau 
of Reclamation to future standards as 
well . 



Response 

By executing the Coordinated Operation 
Agreement, the Secretary of the Interior 
will be agreeing to operate the Central 
Valley Project to meet water quality 
standards set forth in Exhibit A and to 
consider future standards pursuant to 
Article 11, which is discussed in more 
detail in the general issue on future 



standards. The Coordinated Operation 
Agreement does not reauthorize the 
Central Valley Project. Consequently, 
it will not be executed on behalf of 
the Secretary of the Interior unless 
a statute is enacted authorizing the 
Secretary to execute and perform it. 

Water quality standards in Exhibit A, 
taken from State Water Resources Control 
Board Water Right Decision 1485, are for 
the Sacramento-San Joaquin Delta. By 
authorizing the Secretary of the 
Interior to sign the Agreement, Congress 
will have permitted the Secretary to 
significantly increase authorized 
Central Valley Project operations for 
water quality, adding to previously 
authorized water quality operations of 
the New Melones Reservoir for the San 
Joaquin River. 

Congressional actions defining 
authorized purposes of the Central 
Valley Project have evolved over the 
past 50 years. These actions have shown 
a continual responsiveness to the 
changing needs of water development in 
California. Important purposes such as 
fish and wildlife, recreation, and water 
quality have been incorporated, along 
with the initial purposes of river 
regulation, navigation, flood control, 
irrigation, and power. Article 11, for 
incorporating future standards into the 
Coordinated Operation Agreement, is 
consistent with previous actions 
developed to maintain long-term 
responsible operation of the project. 

In addition to the many congressional 
actions that have specifically defined 
authorized purposes of the Central 
Valley Project, environmental protection 
laws continue to influence project 
development and operations. These laws 
pertain to both Federal and State 
projects. Laws such as the National 
Environmental Policy Act, California 
Environmental Quality Act, Endangered 
Species Act, Fish and Wildlife 
Coordination Act, and wilderness and 
wild river legislation directly 



affect projects through mitigation 
requirements and, therefore, often 
influence project development and 
operation for environmental purposes 



Decision 1485 Standards 



Issue 



Although the Coordinated Operation 
Agreement commits both parties to 
standards equivalent to State Water 
Resources Control Board Decision 1485 
Delta water quality standards (Exhibit A 
standards) , these standards are inade- 
quate environmental protection. 



Response 

The intent of the Coordinated Operation 
Agreement is to comply with, rather than 
to update, established standards for 
environmental protection. Exhibit A of 
the Agreement is the set of flow stand- 
ards, water quality standards, and ex- 
port restrictions that define the Delta 
portion of in-basin use requirements ; it 
is taken from the Delta water quality 
and flow standards of Decision 1485. 

The State Water Resources Control Board 
has established authority in connection 
with Decision 1485. The decision was an 
exercise of the Board's reserved juris- 
diction to establish or revise terms and 
conditions for salinity control and 
protection of fish and wildlife and to 
coordinate the terms of the various 
permits for the two projects. The 
Board's authority to review and amend 
these permits is derived from Sections 
100 and 1394 of the California Water 
Code, Section 763.5 of Title 23 of the 
California Administrative Code, and 
jurisdiction expressly reserved in 
previous permits. 

Determination of the adequacy or inade- 
quacy of Decision 1485 standards will 
involve comprehensive public hearings 
where testimony will be received from 



numerous scientists, agencies, and other 
Delta interests. State Water Resources 
Control Board staff will evaluate the 
testimony and propose future standards 
for the Board's consideration. The 
Board will then use its authority to 
establish new standards. It would not 
be reasonable or possible for negotia- 
tiirs of the Coordinated Operation 
Agreement to bypass this process or the 
Board's authority. However, the Coordi- 
nated Operation Agreement provides a 
method to incorporate new standards once 
they are adopted. 

Exhibit A standards are for protection 
of beneficial uses of water in the 
Sacramento-San Joaquin estuary, 
including municipal and industrial, 
agricultural, and fish and wildlife 
uses. These standards are based on the 
principle that water quality in the 
Delta should be at least as good as it 
would have been had State and Federal 
water projects not been constructed, as 
limited by the constitutional mandate of 
reasonable use. The State Board 
recognized that the standards might not 
achieve pre-project levels for some fish 
species, but deemed the level of protec- 
tion reasonable until better ways could 
be found to mitigate project impacts. 

Additional information is being gathered 
on Delta ecology, and the State Board 
will review the standards in connection 
with beneficial uses of Delta water sup- 
plies. On January 17, 1985, the State 
Board adopted Resolution 85-4, which 
contains a general schedule of actions 
to resolve outstanding water quality 
control and water rights issues relative 
to the Bay-Delta estuary. This schedule 
provides that the hearing process on 
these issues will begin in November 1986 
(scoping) and a new plan finalized in 
1989. This 3-year schedule is indica- 
tive of the complexity of the issues 
surrounding evaluation and revision of 
Delta standards. Also, this review 
process by the Board shows that estab- 
lishing Delta standards involves a 
dynamic process and that all areas of 
concern must be regularly investigated. 



This includes ongoing studies and 
monitoring. Protection for fish is one 
area, and this will include reviewing 
problems of toxic pollution. Providing 
protection against toxic pollution is 
beyond the operational capabilities of 
the projects. 

Article 11 is included in the Agreement 
to deal with these future standards; the 
basis for its wording is discussed in 
response to the general issue on future 
standards. In the period before 
possible new standards, adoption of 
Exhibit A standards will provide greater 
protection for the Delta than without 
these standards. 

Exhibit A standards provide more envi- 
ronmental protection than the Bureau's 
present water quality requirements, 
known as Tracy standards, by adding 
about 100 new protective criteria at 15 
additional stations. There are several 
fishery benefits from Exhibit A, 
including: 

Joint commitment of about 2.3 million 
acre- feet of water supply for Delta 
outflow during critical water supply 
periods to meet Exhibit A standards 
for protection of the environment. 
This supply is removed from being a 
potential export source and will 
provide a benefit by eliminating the 
direct entrainment of fish at both the 
Federal and State Delta export facili- 
ties that could occur without a com- 
mitment to Exhibit A standards. The 
benefit will be for the many Delta 
fish species, including fish eggs, 
larvae, and food supply. 

Improvement of water quality condi- 
tions near the Antioch Water Works 
intake to benefit striped bass 
spawning . 

Added Delta outflow and quality at 
Chipps Island to benefit striped 
bass survival and salmon migration. 

Added Sacramento River flows at Rio 
Vista to benefit salmon migration. 



10 



Diversion limitations in May, June, 
and July to minimize entrainment 
and to benefit young striped bass. 

Closure requirements for the Delta 
Cross Channel for certain conditions 
from mid-April through May to benefit 
striped bass by minimizing the number 
diverted into the central Delta. 

Improvement of several flow and 
quality conditions for agricultural, 
municipal, and industrial use, which 
indirectly provides fishery benefits. 

These benefits will result from use of 
project supplies for environmental 
protection versus other options such as 
exporting the supplies. This change in 
use of supplies can result in changes in 
project operations. 

In addition to the protective criteria 
contained in the Coordinated Operation 
Agreement, the associated commitment of 
water to the environment, and the 
ongoing review and monitoring process by 
the Board, there are numerous laws, 
policies, guidelines, physical measures, 
and studies designed to add to the 
environmental protection of the Delta. 
Many of the studies involve State Water 
Project and Central Valley Project funds 
to advance environmental protection 
measures above Exhibit A criteria. 
These additional measures are discussed 
below. 

Federal and State laws and policies show 
that commitments to protect the environ- 
ment are directly and indirectly in 
place to benefit the Delta. These 
include : 



Federal Government — 

" Fish and Wildlife Coordination Act 
" National Environmental Policy Act of 
1969 



Clean Water Act of 1977 
Endangered Species Act of 1973 
Land and Water Conservation Fund Act 
Principles and Standards for Planning 
Water and Related Land Resources 
U. S. Fish and Wildlife Service Guide- 
lines for Review of Fish and Wildlife 
Aspects of Proposals In or Affecting 
Navigable Waters, December 1975 
Regulatory Programs of the U. S. Army 
Corps of Engineers 
Regulatory Program of the Environ- 
mental Protection Agency in Navigable 
Waters 

Concept Plan for Waterfowl Wintering 
Habitat Protection 



State of California — 

Delta Protection Act 
' Davis-Dolwig Act of 1961 

California Environmental Quality Act 

of 1970 
" Fish and Game Code, Section 1600 

California Endangered Species Act of 

1973 

Senate Concurrent Resolution No. 28, 

1978 
" Keene-Nejedly Wetlands Preservation 

Act of 1976 

Fisheries Restoration Act of 1985. 
° California Fish and Wildlife Plan, 

1966 
° California Fish and Game Commission 

Resolution, February 9, 1973 
° Department of Fish and Game Position 

on Delta and Suisun Marsh Wildlife 

Conservation by a Delta Water 

Facility, November 1975 
° Resources Agency Policy for Preserva- 
tion of Wetlands in Perpetuity, 1977 

Many of the laws and policies are broad 
guidelines for protecting, among other 
things, fish and wildlife resources of 
the estuary system. These measures have 
been instrumental in guiding water 
resources planning and in defining 
mitigation responsibilities. 



11 



Facilities constructed and planned by 
the Department of Water Resources and 
Bureau of Reclamation to protect fish 
and wildlife provide specific types of 
benefits which are discussed below. 

Reservoir Releases: To maintain flow 
requirements to protect fish and 
wildlife in the Delta, a portion of 
upstream reservoir storage must be 
reserved for releases to Delta outflow. 
Upstream releases from Oroville, Shasta, 
Clair Engle, Lewiston, and Folsom 
reservoirs required by the Coordinated 
Operation Agreement for protection of 
fish and wildlife resources have 
estimated values of about $100 million 
to $300 million if compared to the 
development of new supplies at $100 to 
$300 per acre- foot. 

John E. Skinner Delta Fish Protective 
Facility: This $5 million facility, 
recently enlarged at a cost of an addi- 
tional $4.5 million, is on the intake 
channel of Banks Pumping Plant, adjacent 
to Clifton Court Forebay. The facility 
screens and salvages fish from export 
water . 

Tracy Fish Collecting Facilities: This 
$3 million facility, constructed and 
operated by the Bureau of Reclamation, 
diverts and collects fish from the 
intake channel to Tracy Pumping Plant. 
It was developed through an exploratory 
program conducted jointly by the Bureau 
and the Fish and Wildlife Service. This 
facility is part of the Central Valley 
Project . 

Hatcheries: Although outside the bound- 
aries of the Delta, several State and 
Federal hatcheries contribute to fish 
populations in the Sacramento-San 
Joaquin river system and help protect 
anadroraous fish within the Delta. Major 
hatchery facilities are Nimbus Hatchery 
on the American River, Feather River 
Hatchery, and Coleman National Fish 
Hatchery on Bottle Creek (a tributary to 
the upper Sacramento River). Smaller 
facilities include Tehama-Colusa Fish 
Facility on Coyote Creek, Mokelumne 



River Fish Installation, Elk Grove 
Fish Hatchery, and Merced River Fish 
Facility. 

Old River Closure: During the fall of 
drier years, a reach of the San Joaquin 
River near Stockton sometimes becomes 
depleted of dissolved oxygen due to low 
inflow and the decompositon of waste 
materials discharged into the river. 
The shortage of dissolved oxygen blocks 
upstrean migration of adult salmon. 
When this occurs, the Department of 
Water Resources constructs a temporary 
rock barrier across the head of Old 
River in the southern Delta, forcing 
more water into the San Joaquin River to 
remove the dissolved oxygen block. Each 
time the barrier is placed and removed, 
it costs the Department about $50,000. 
The Department of Fish and Game has 
determined this closure to be effective 
in reducing stress to migrating salmon. 

Protection requires knowledge of the 
Delta's environment including studies 
and monitoring. Studies for Delta 
protection have ranged from individual 
studies of species to broad conservation 
plans. The Department of Water 
Resources and U. S, Bureau of Reclama- 
tion have provided significant funding 
for these studies, which have added and 
will continue to add to protection for 
the Delta. A tremendous amount of 
information has been gained, but it is 
not yet known how all the individual 
pieces of information interact. The 
ecological investigations of the Delta 
have faced several unique conditions, 
including the many complex factors that 
affect the Bay-Delta estuary: 

Land reclamation. 

Waste water effluent and surface 

runoff from local and upstream urban 

development . 

Oil spills. 

Drainage and leaching water discharge 

from Delta and upstrean agricultural 

use, including drainage from San 

Joaquin Valley. 

Commercial, sport, and illegal 

fishing. 



12 



Construction and maintenance of deep 
water ship channels. 
Use of natural inflows by upstream 
agricultural and urban development. 
Upstream storage and regulation of 
natural inflows by more than 500 
reservoirs, including those of the 
Central Valley Project, State Water 
Project, Hetch Hetchy Aqueduct 
Project, Mokelumne Aqueduct Project, 
and local projects. 
Diversions by the Central Valley 
Project, State Water Project, local 
municipal and industrial users, and 
Delta agricultural water users. 
Levee failures. 

Ecological studies will advance 
knowledge on how factors such as those 
listed above affect the Delta and 
identify measures that can be taken to 
reduce the impacts of these factors. 

Recent and ongoing studies are discussed 
below. 

Interagency Ecological Study Program: 
These are cooperative studies by the 
Department of Fish and Game, Department 
of Water Resources, U. S. Fish and 
Wildlife Service, U. S. Bureau of 
Reclamation, U. S. Geological Survey, 
and State Water Resources Control Board. 
(These studies were mentioned in the 
response to the general issue on the 
striped bass decline.) They are for the 
purpose of obtaining a thorough under- 
standing of the estuary in order to: 

Gain insight into fish and wildlife 
requirements in the Bay-Delta system. 

Develop design and operating criteria 
for the State Water Project and 
Central Valley Project for protection 
and enhancement of fish and wildlife. 



follows: Department of Water Resources, 
$20,000,000; Department of Fish and 
Game, $13,000,000; and U. S. Bureau of 
Reclamation, $9,000,000. 

The interagency program consists of five 
study elements: fisheries, water 
quality, fish facilities, Suisun Marsh, 
and San Francsico Bay. The study 
elements are described briefly below. 

Fisheries, Examines the environmental 
requirements of chinook salmon, 
striped bass, and resident fish such 
as v^ite catfish and largemouth bass 
and the impact of water projects on 
these requirements. Field sampling is 
used to index abundance, and these 
indices are compared to variables such 
as flow, pumping, food supply, 
temperature, and toxicants to 
determine what variables control 
population size. 

Water Quality. Examines factors con- 
trolling abundance and distribution of 
floating algae in the Delta and Suisun 
Bay. These microscopic plants form 
the basis of most food chains in the 
aquatic environment. The study also 
collects data on zooplankton, the 
small animals that graze on the 
algae. 

Fish Facilities. Develops information 
needed to build effective fish 
protective systems in the Delta and 
elsewhere and to evaluate the 
effectiveness of existing facilities. 

Suisun Marsh. Develops physical 
facilities that allow use of available 
water for maintaining duck habitat in 
the marsh. Evaluates effectiveness of 
the facilities for meeting the 
objectives . 



° Monitor project operations and modify 
operating criteria as necessary. 

Total funding under the program has been 
over $40,000,000 from 1971 through 
June 30, 1984, which has been shared 
among three agencies approximately as 



San Francisco Bay. Two major 
elements, biological and hydrodynamic , 
provide information regarding effects 
of freshwater flow on distribution and 
abundance of fish and identify circu- 
lation patterns in the lower estuary. 



13 



In addition to the Interagency studies, 
other ecological studies and monitoring 
have been or are being conducted to 
advance knowledge of the Bay. These are 
discussed below. 

° Cooperative Striped Bass Study: This 
study, funded by the State Water 
Resources Control Board, investigated 
relationships between toxic materials 
in San Francisco Bay and Delta waters 
and problems with the striped bass 
population. The study was conducted 
by the National Marine Fisheries 
Service in cooperation with the 
Department of Fish and Game. 

° Striped Bass Stamp Fund: The 

Department of Fish and Game manages 
studies funded by striped bass stamp 
monies and coordinates the striped 
bass artificial propagation program. 

Aquatic Habitat Program: The goals of 
this program, administered by the San 
Francisco Bay Regional Water Quality 
Control Board, are to (1) evaluate 
present and future effects of 
pollutants on beneficial uses in San 
Francisco Bay and the Delta, and 
(2) determine possible ways to achieve 
a more centralized direction of all 
water-related Bay studies, including 
general research. Bond monies 
budgeted are in excess of $600,000. 

Related State Water Resources Control 
Board Activities: The Pollutant 
Investigations Branch monitors and 
studies toxics in the estuary. San 
Francisco Bay Regional Water Quality 
Control Board has several studies, 
including nonpoint source loadings in 
South Bay, Napa River bacteriological 
study, and San Francisco Bay shellfish 
harvesting . 

At the request of the State Water 
Resources Control Board, a group of 
scientists investigated causes of the 
striped bass decline to identify 
corrective action. The group's 
recommendations have resulted in the 



Export Curtailment Experiment, which 
is aimed at (1) determining the 
effects of State Water Project and 
Central Valley Project exports on food 
chain (phytoplankton and zooplankton) 
development and abundance during 
larval stages of striped bass in the 
estuary and (2) determining the 
relative importance of these effects 
in comparison to other factors 
affecting the food chain. 

Water Right Decision 1485 requires 
monitoring Delta conditions to ensure 
that flow and quality standards estab- 
lished by the State Water Resources 
Control Board for environmental 
protection are met. Monitoring is 
closely coordinated with the Inter- 
agency Ecological Study Program. 
Funds for 1984-85, provided by the 
State Water Project contractors, are 
in excess of $1.9 million. 



Future Standards/ 
Termination Provisions 

I ssue 

The Coordinated Operation Agreement does 
not commit the Bureau of Reclamation 
to any new or revised standards. The 
Environmental Impact Statement/Report 
should address the requirement for the 
Bureau of Reclamation to meet current 
and future Delta water quality standards 
under Section 313 of the Clean Water 
Act. Also, the Coordinated Operation 
Agreement is of limited duration because 
of all the termination provisions. 



Response 

Commitment by the Bureau of Reclamation 
to any new or revised standards is an 
important and complex issue. During the 
long negotiations for this proposed 
agreement this issue was resolved by 
development of agreement provisions to 
meet three objectives. 



14 



1. A guarantee that existing standards 
be implemented by both projects, 

2. A defined procedure to include 
future standards. 

3. Maintenance of legal neutrality 
with the 1978 U. S. Supreme Court 
decision California vs. United 
States . 

Article 11 of the Agreement meets 
the above objectives and provides a 
practical approach to eliminating a 
potential impasse in negotiations. 

Article 11 requires the Bureau of 
Reclamation to operate the Central 
Valley Project to meet Exhibit A 
standards and allows the Secretary of 
the Interior to accommodate a future 
change in water quality standards 
through amendment of Exhibit A without 
renegotiation of other provisions of the 
Coordinated Operation Agreement. Under 
the provisions of Article 11, if new 
standards are adopted, Federal 
decision-makers will determine whether 
operation of the Central Valley Project 
in conformity with the new standards is 
consistent with congressional 
directives. If so. Exhibit A of the 
Agreement will be amended to conform 
with the new standards. If not, the 
Bureau of Reclamation will promptly 
request that the Department of Justice 
bring a legal action to determine 
whether the new Delta standards should 
be considered binding on the Central 
Valley Project. 

Article 11 does not require the 
Secretary to unconditionally accommodate 
all future changes in such standards 
because the 1978 U. S. Supreme Court 
decision California vs. U . S . , 
438U.S.645, holds that the Central 
Valley Project must be operated to meet 
only those conditions contained in its 
water right permits that are not 
inconsistent with congressional 



directives. Recognition of that 
decision is incorporated in Article 11 
of the Coordinated Operation Agreement 
and is not inconsistent with Section 313 
of the Clean Water Act. 

The Bureau of Reclamation and the State 
of California realized that more 
specific provisions regarding 
applicability to the Central Valley 
Project of water quality standards other 
than those in Exhibit A could not be 
incorporated without an ability to 
foretell the scope and details of future 
actions by the State Water Resources 
Control Board. Accordingly, Article 11 
requires the Bureau of Reclamation to 
evaluate impacts of any new State 
standards through additional operation 
studies and to determine whether those 
new standards are consistent or 
inconsistent with congressional 
authorization of the Central Valley 
Project. 

If the State Water Resources Control 
Board adopts new standards and Exhibit A 
is not amended, the Central Valley 
Project will continue to be operated to 
comply with the Exhibit A standards. 

The Coordinated Operation Agreement was 
designed to bind both the State and 
Federal projects to coordinated 
operation in perpetuity. Flexibility to 
amend the agreement, where necessitated 
by changed circumstances such as the 
construction of additional facilities 
(built into Article 14) and future 
standards (built into Article 11) is 
included. This flexibility was provided 
for the specific purpose of maintaining 
agreement even when inevitable changes 
occur in the water supply and operations 
picture. Provisions allow for termina- 
tion (Article 14(b)(1) and (2)) if: 

A contract for the purchase and 
conveyance of water is not agreed 
to by December 31, 1988 
(Article 10(h)(1)); 



15 



* Amendments to water right permits 
are not received (Article 
10(h)((4)); or 

* After periodic review, the parties 
fail to reach agreement on 
revisions • 

The possibility of termination of the 
Coordinated Operation Agreement within 
5 years arises in the context of 
subarticles 10(h) and 14(b), However, 
a significant incentive is future water 
resources planning needs for both the 
Central Valley Project and the State 
Water Project that could be met in part 
by successful negotiations between the 
Bureau of Reclamation and the Department 
of Water Resources for an agreement on 
purchase and conveyance of the Central 
Valley Project water pursuant to 
subarticle 10(h) . 

Both agencies must subsequently work 
with the State Water Resources Control 
Board to obtain permits required to 
implement such an agreement. These 
project demands are important enough to 
each agency to ensure that good faith 
efforts will be applied to negotiating 
an agreement under subarticle 10(h) 
rather than terminating the Coordinated 
Operation Agreement for failure to reach 
such an agreement. Moreover, the term- 
ination provision in subarticle 14(b) is 
optional, not mandatory. Thus, even if 
the agencies fail to reach agreement on 
the contract provided for in subarticle 
10(h), they may have crucial policy 
concerns that will make it more 
expedient to continue coordinated 
operation rather than terminate the 
Agreement . 

With the Agreement in place, priority is 
given to Delta environmental protection, 
including water quality control. This 
priority is an intent of the Agreement, 
and no provision in the Agreement alters 
this intent. 

Article 14 provides for review of 
project operations every 5 years, or 



more frequently if requested by either 
party. The Bureau and the State have 
spent at least 25 years conducting joint 
operation studies and negotiating an 
agreement to provide for coordinated 
operations because it is to their mutual 
advantage to have such an agreement . 
Subarticle 14(b) provides for an 
advisory board to assist v^en there is 
extreme disagreement on changes to the 
Coordinated Operation Agreement 
specifically because both parties want 
to maintain the agreement finally 
negotiated. Given the history of these 
efforts, it is unlikely that either 
party would casually seek to terminate 
the Coordinated Operation Agreement. 
Both parties recognize the necessity of 
coordinated operation to the projects 
and to overall public interest. 



Future Water Marketing 



Issue 



The Coordinated Operation Agreement will 
end the Bureau of Reclamation moratorium 
on additional water contracts. The 
Draft Environmental Impact Statement/ 
Report failed to fully address the 
incremental or cumulative impacts of 
future water marketing. 



Response 

The Coordinated Operation Agreement does 
not authorize new water delivery 
contracts. The Agreement does require 
that both the State Water Project and 
the Central Valley Project commit about 
2,3 million acre-feet of water during a 
critical water supply period to provide 
environmental protection. This supply 
is removed from any potential future 
water supply contract. However, 
separate from the Agreement, the Bureau 
of Reclamation is planning for future 
marketing of water. Any future contract 
will require new agreements separate 
from the Coordinated Operation Agreement 
and will require the Bureau of 



16 



Reclamation to meet all requirements of 
governing policy and law. Both Bureau 
of Reclamation policy and Federal law 
require that environmental concerns be 
appropriately addressed before new 
contracts are executed. Meeting the 
water quality standards identified in 
the Coordinated Operation Agreement is a 
major action being taken by the Bureau 
of Reclamation to satisfy a significant 
aspect of Delta environmental 
protection. 

The Bureau of Reclamation is preparing 
environmental impact statements on 
future water marketing for the Central 
Valley Project. Analyses in these 
documents will include site-specific 
discussions of impacts within each 
marketing area and cumulative impacts 
that result from the incremental impacts 
of marketing water when added to past, 
present, and foreseeable future actions 
projectwide. The depth of the analysis 
and the range of alternatives selected 
for analysis will vary depending on 
marketing demands and the issues identi- 
fied as significant by the public, the 
Bureau, and other affected agencies dur- 
ing the scoping process. These issues 
may include an analysis of surface water 
and ground water quality, soil salinity 
and toxicity, subsidence, fish and 
wildlife (including water supplies for 
refuges), endangered species, flood- 
plains and wetlands, drainage, seepage 
and streambank erosion, recreation, 
cultural resources, land use changes 
resulting from water marketing, 
socioeconomic factors, and power 
production. 

Planning for future Central Valley 
Project water supply contracts was 
addressed on pages 94 to 100 of the 
draft report (see sections on Cumulative 
and Growth Inducing Impacts ; Wheeling 
Arrangements; Purchase of Central Valley 
Project Water by the State Water 
Project; Removal of the Moratorium on 
New Water Service Contracts ; Mitigation 
Measures for Cumulative Impacts ; and 
Table 15, Expected Environmental Effects 
of Possible Future Actions). These 



discussions of future water marketing 
are more general than what is expected 
for future environmental reports on this 
matter, since the exact nature of future 
contract amounts and locations cannot be 
predicted. 



Salmon 



Issue 



The Coordinated Operation Agreement 
will cause temperature problems (and 
related salmon problems) in the Trinity 
and Sacramento rivers and flow problems 
in the American and San Joaquin rivers. 
These impacts were not addressed 
sufficiently, and no mitigation was 
included . 



Response 

Potential changes in river temperatures 
resulting from changes in project 
operations, and associated effects on 
salmon spawning, are an important 
concern. The draft report acknowledged 
the importance of such changes and pro- 
vided a detailed analysis of potential 
temperature changes attributable to the 
Agreement. Potential salmon impacts 
presented in the draft report for the 
proposed action represent incremental 
mortalities based on a worst-case 
analysis designed to maximize impacts. 
These impacts are not "actual" impacts, 
nor are they likely to occur as pre- 
sented. This type of analysis is 
consistent with the needs of an environ- 
mental assessment. However, interpreta- 
tion of worst-case results should 
recognize the probability of occurrence 
by comparison to actual conditions. A 
review of the worst-case evaluation by 
comparison to actual operations, along 
with consideration of the provisions for 
salmon protection in the Agreement, led 
to the judgment that impacts to salmon 
would not be significant. 

The comparison and findings for this 
Agreement do not imply that temperature 



17 



control for fish protection in the 
Sacramento and Trinity rivers is 
unimportant. Separate studies are 
reviewing protective measures for this 
concern. Also, this impact evaluation 
does not imply that trading upstream 
habitat for Delta habitat is a strategy 
of the Coordinated Operation Agreement. 
The Agreement was developed to provide a 
reliable and mutually acceptable basis 
for coordinating operations while 
protecting the water-related environment 
of the Delta. 

The analysis in the report used an 
assumed condition in which the 
difference in flow between meeting Tracy 
standards and Exhibit A standards is 
retained in upstream reservoirs and 
thereby allowed better temperature 
control without the proposed Agreement. 
The result was that some incremental 
temperature increases were associated 
with the Agreement. The probability of 
occurrence of this worst-case is very 
low, since it assumes that about 
2 million acre- feet of water in upstream 
reservoirs would be left completely 
unused through a critical water supply 
period if it were not used for Delta 
protection as defined in the Agreement. 
This would occur concurrent with 
statewide water shortages. 

This worst-case scenario for the Agree- 
ment showed that temperature changes 
could occur in less than 4 percent of 
the years studied. This change could 
cause a 4 percent total salmon run loss 
with present conditions and 8 percent in 
2020. Reducing the capability of the 
Central Valley Project to control water 
temperatures for salmon spawning in the 
rivers below its major reservoirs during 
critical years is a potential adverse 
environmental impact (discussed in 
detail on pages 74 to 77 of the draft 
report) . To the extent that Decision 
1485 standards protect these resources, 
meeting these standards is judged more 
beneficial to the environment than not 
meeting them. If any of the supply that 
was assumed to be retained in storage 
were released under actual conditions. 



then any incremental differences in 
temperature would be reduced. If all 
the supply were used, then the impact 
differential between no-project and 
worst-case would be eliminated, and any 
impacts associated with the Agreement 
would also be eliminated. Comparison, 
actual conditions during the 1976-1977 
drought were used to represent critical 
conditions. 

Evaluation of actual conditions during 
the drought revealed the following. 

* Water supplies were not retained in 
reservoir storage as assumed for the 
worst-case analysis in the draft 
report. Delta emergency standards 
were in effect and required less 
storage than Exhibit A standards. 

° Actual temperatures considered lethal 
to salmon (above 60 °F) did occur in 
upstream spawning areas during July 
through September. These temperatures 
occurred without the present agreement 
and approach or equal conditions 
similar to the worst-case increases 
predicted for the Agreement. This 
suggests that such conditions may 
occur with or without the Agreement . 
Coordinated operation of the State 
Water Project and Central Valley 
Project reduced these temperature 
impacts considerably during October 
through January. 

Salmon returns 3 years after the 
1976-1977 drought showed no signifi- 
cant reductions in population numbers. 
Commercial catch values actually 
increased in the 1979 to 1980 
post-drought period. These returns 
were based on 1979 and 1980 commercial 
catch and escapement records. 

Based on this comparison and the facts 
listed below, the potential impacts to 
salmon were determined not to be 
significant . 

Temperature increases from using 
available stored water during a 
drought will probably occur without 



18 



the Agreement and are largely 
independent of the Agreement. 

Limited temperature increases above 
60°F that occurred in 1976 and 1977 
did not appear to substantially impact 
salmon runs. 

Provisions for salmon protection in 
the Agreement include maintenance of 
flows in the Sacramento River at Rio 
Vista for salmon migration. Also, 
the Agreement includes export 
restrictions . 



Striped Bass Decline 



Issue 



Striped bass populations have continued 
to decline with Decision 1485 standards, 
as demonstrated by recent striped bass 
index calculations, yet the Coordinated 
Operation Agreement neglects to commit 
the Bureau of Reclamation or the Depart- 
ment of Water Resources to any standards 
that provide greater protection than 
Exhibit A. Also, the Draft Environmen- 
tal Impact Statement/ Re port does not 
discuss striped bass index 
calculations . 



Exhibit A standards will afford the same 
level of protection. Effects due to 
other factors are under investigation. 
Both agencies have taken steps, along 
with others, to reverse the decline and 
to improve methods to predict popula- 
tions. These steps include commitments 
in connection with the Coordinated 
Operation Agreement. Also, studies by 
other agencies, physical measures, laws, 
policies, and guidelines are protective 
measures that go beyond the protection 
included in Exhibit A. These other 
measures are discussed in the response 
to the general issue on Decision 1485 
standards. 

Commitments in the Coordinated Operation 
Agreement were discussed in the draft 
report. Key points include the 
commitment of 2.3 million acre-feet of 
project yield during a critical water 
supply period for outflow to meet about 
100 separate environmental protection 
criteria for the Delta taken from Water 
Right Decision 1485. Decision 1485 
criteria for striped bass protection 
include : 

Electrical conductivity requirements 
at Prisoners Point and at the Antioch 
Water Works intake on the San Joaquin 
River . 



Response 

The Department of Water Resources and 
the Bureau of Reclamation recognize 
striped bass and other fish species to 
be a valuable State resource and, along 
with other agencies, have programs in 
place to resolve this problem. However, 
specific changes to Decision 1485, if 
any, needed to reverse the striped bass 
decline are not yet known. Decision 
1485 standards only relate to factors 
involving water project operations. 
Factors other than project operations, 
such as toxics and other pollution, may 
be contributing to the recent striped 
bass decline. 



Minimum Delta outflow requirements 
from January through July. 

Curtailment of State Water Project and 
Central Valley Project exports in May, 
June, and July of all year types. 

Constraints on operation of the Delta 
Cross Channel gates in April and May 
to minimize diversion of young striped 
bass into the central Delta, 

Although changes to these criteria may 
be needed, meeting these standards is 
better than not meeting them and this is 
an added commitment beyond the no- act ion 
alternative. 



To the extent that established Decision 
1485 standards protect striped bass from 
effects due to project operations. 



In August 1981, the State Water 
Resources Control Board published a 
Prehearing Staff Report, Triennial 



19 



Review of the Water Quality Control Plan 
to provide a review of the plan and 
Decision 1485 standards, as required by 
law. During this review, the Department 
of Fish and Game submitted information 
and recommendations regarding the 
striped bass decline. Fish and Game 
indicated that the decline "may be 
related to causes other than Delta 
operation of the Central Valley Project 
and State Water Project or the current 
Delta Plan striped bass survival 
standards". Fish and Game further 
suggested that factors other than 
outflow and diversions in spring and 
summer are directly responsible for the 
decline in abundance of juvenile striped 
bass . 

The more recent Striped Bass Working 
Group study focused specifically on 
striped bass. At the request of the 
State Water Resources Control Board, a 
group of scientists investigated causes 
of the striped bass decline to identify 
corrective action. Four possible causes 
were examined: 

" Production of food for young striped 
bass has been reduced. 

* Large numbers of eggs and young bass 
are diverted from the estuary with 
water needed for agriculture, power 
plant cooling, and other uses. 

' Point and nonpoint discharges of 

pesticides and petroleum products may 
increase mortality of adults, reduce 
their ability to reproduce, or reduce 
the survival of eggs and young. 

° The adult population, reduced by a 
combination of declining numbers of 
juveniles and higher mortality rates, 
produces fewer eggs. 

Although no conclusions have been 
reached, the group's recommendations 
have resulted in an interagency flow 
management experiment to determine: 

° The effects of State Water Project and 
Central Valley Project exports on food 



chain ( phyto plankton and zooplankton) 
development and abundance during 
larval stages of striped bass in the 
estuary. 

° The relative importance of these 

effects in comparison to other factors 
affecting the food chain. 

Information obtained has not yet led to 
conclusions. 

Commitments by the Department of Water 
Resources and Bureau of Reclamation 
beyond those in the Coordinated 
Operation Agreement include funding a 
significant portion of the $40 million 
spent to date on the Interagency Ecolog- 
ical Study Program. These cooperative 
studies by the Department of Fish and 
Game, Department of Water Resources, 
U. S. Fish and Wildlife Service, U. S. 
Bureau of Reclamation, U. S. Geological 
Survey, and State Water Resources 
Control Board are for the purpose of 
obtaining a thorough understanding of 
the estuary in order to: 

Gain insight into fish and wildlife 
requirements in the Bay-Delta system. 

Develop design and operating criteria 
for the State Water Project and 
Central Valley Project for protection 
and enhancement of fish and wildlife. 

Monitor project operations and modify 
operating criteria as necessary. 

In addition, the Department of Water 
Resources is negotiating with the 
Department of Fish and Game to obtain an 
agreement for operation of Banks Pumping 
Plant. This agreement is expected to 
provide several million dollars for fish 
protective measures to compensate for 
fish that would have been in the Delta 
had the pumping plant not been 
constructed . 

The striped bass index is a correlation 
between historical records of young 
striped bass populations. Delta out- 
flows, and project exports. This index 



20 



has been discussed in connection with 
two different topics: (1) an actual 
yearly measurement of young striped bass 
in the Delta; and (2) in relation to a 
statistical relationship between 
outflows and exports from operation 
studies that simulate future levels of 
development. The first use of the index 
is still valid, and information 
concerning 1985 findings has been added 
to this final report. Uncertainties 
have developed in the area of the second 
topic because predicted values have 
been considerably higher than actual 
values since the 1976-1977 drought. Use 
of the correlation for future conditions 
in this environmental document would 
probably overpredict the index. Work is 
underway to revise this correlation. 



Suisun Marsh 



Issue 



No protection for Suisun Marsh is pro- 
vided for in the Coordinated Operation 
Agreement, and impacts to the marsh have 
not been adequately addressed in the 
Draft Environmental Impact Statement/ 
Report . 



Response 

Protection for Suisun Marsh is an inte- 
gral part of water resources planning 
and is the subject of a separate agree- 
ment between the Bureau of Reclamation, 
Department of Water Resources, Depart- 
ment of Fish and Game, and Suisun 
Resource Conservation District. For 
this reason, the Coordinated Operation 
Agreement included only some of the 
Suisun Marsh standards from Decision 
1485. 

However, the Coordinated Operation 
Agreement was specifically designed to 
include the finalized Suisun Marsh 
protective measures defined by this 
separate action. The Agreement has 
provisions for amendments to integrate 
such new marsh protective facilities 
(Articles 14 and 16). Water quality 



standards pertaining to Suisun Marsh 
would be amended into Exhibit A, and any 
adjustments necessary to the sharing 
formula and Exhibit B would be made in 
accordance with Articles 11 and 6, 
respectively. 

Progress has been made toward protecting 
the marsh. Physical facilities are 
required because protection of the marsh 
with outflow alone during dry periods 
would require excessive quantities of 
water and would likely be considered a 
waste of water under the California 
Constitution and the California Water 
Code. Three of the facilities needed to 
protect water quality in Suisun Marsh 
have already been constructed: Morrow 
Island Distribution System, Goodyear 
Slough Outfall, and Roaring River Slough 
intake. These were constructed with 
project funds at a cost of $10 million. 
Construction of the Montezuma Slough 
Control Structure is to begin in June 
1986; completion is scheduled for fall 
1988. This facility is expected to 
protect about 80 percent of the marsh 
and has a projected cost of about 
$20 million. The need for additional 
facilities will be determined by 
examining effects on water quality of 
operating these facilities. The cost 
for additional facilities may increase 
total costs to $120 million. 

Legislation is required to authorize the 
Secretary of the Interior to financially 
participate in construction of facili- 
ties contemplated by the 4-party agree- 
ment negotiated in August 1985. This 
legislation could be passed concurrent 
with or as part of legislation 
authorizing the Coordinated Operation 
Agreement . 

The primary objective of the Suisun 
Marsh Preservation Agreement is to 
assure a dependable water supply to 
mitigate adverse effects by the Central 
Valley Project and State Water Project 
and a portion of the adverse effects of 
other upstream diversions. This will be 
accomplished by implementing the plan of 
protection, including construction of 
facilities . 



21 



The agreement defines water quality 
standards that in most years are similar 
to those provided under Decision 1485, 
except the agreement provides for 
relaxation of the standards in a series 
of dry or critical years. The parties 
to the agreement are to jointly petition 
the State Water Resources Control Board 
to substitute the agreement for the 
marsh standards in the Central Valley 
Project and State Water Project water 
right permits. 

The agreement defines a schedule and 
sequence of construction for facilities 
of the plan of protection. It provides 
for test periods during which the effec- 
tiveness of facilities constructed to 
date is to be evaluated. Assessments 
will then be made to determine if addi- 
tional facilities will be needed to meet 
the water quality standards of the 
agreement . 

The Bureau of Reclamation is to pay 
40 percent of the costs of the 
facilities, including operation and 
maintenance, with a Federal construction 
cost ceiling of $50 million in 1985 
dollars. The Department of Water 
Resources will pay the balance, 40 per- 
cent paid by the State Water Project and 
20 percent from funds appropriated by 
the Legislature for impacts caused by 
other upstream diverters. Neither 
agency will be liable for the other's 
obligations under the agreement. 

Two additional subsidiary agreements 
between the Bureau of Reclamation, the 
Department of Water Resources, and the 
Department of Fish and Game are 
involved. One covers soil salinity and 
channel water quality monitoring, and 
the other provides for the acquisition 
and development of lands to mitigate for 
impacts of constructing the Suisun Marsh 
facilities and for impacts on the 
channel islands that cannot be served by 
facilities. The cost of both functions 
will be shared on the same basis. 

The monitoring agreement for Suisun 
Marsh is between the U. S. Bureau of 
Reclamation, Department of Water 



Resources, and Department of Fish and 
Game. The objective is to establish 
methodology for the monitoring program 
to carry out objectives of the Suisun 
Marsh Preservation Agreement. Fish 
habitat studies will be funded through 
the Interagency Ecological Study 
Program. Every 5 years the prograoa will 
be reviewed to see if it can be reduced. 
Soil salinity monitoring will be 
discontinued after September 30, 1990. 

The mitigation agreement for Suisun 
Marsh is between the same parties as the 
monitoring agreement. The objective of 
this agreement is to mitigate for 
wetlands lost because of facilities 
constructed in accordance with the 
Suisun Marsh Preservation Agreement and 
due to the impact of the Central Valley 
Project and State Water Project and 
other upstream diverters on the channel 
islands. At first, the Department of 
Fish and Game will be given about 
$3 million by the Department of Water 
Resources and the Bureau of Reclamation 
to acquire, develop, and operate lands 
to compensate for impacts of the Initial 
Facilities, the Montezuma Slough Control 
Structure, and half the impacts on the 
channel islands. When additional 
facilities are to be constructed, 
additional mitigation land funding will 
be provided. By September 30, 1997, the 
second half of the funding for channel 
island impacts will be furnished. 



San Francisco Bay 



Issue 



The Coordinated Operation Agreement 
provides no protection for San Francisco 
Bay, and impacts to the Bay were not 
adequately addressed in the Draft 
Environmental Impact Statement/Report. 



Response 

San Francisco Bay, a valuable resource, 
has been the subject of intensive eco- 
logical research for many years. Many 
complex physical, chemical, and biologi- 



22 



cal components interact in San Francisco 
Bay. The Department of Water Resources, 
the Bureau of Reclamation, and others 
are working toward a better understand- 
ing of how water projects; point 
discharges, surface runoff, and other 
toxic pollution sources; land 
reclamation; and commercial fishing 
influence the estuary. Various reports 
have been printed describing preliminary 
findings. When the State Water 
Resources Control Board developed and 
issued Water Right Decision 1485, 
insufficient information precluded the 
Board from adopting specific standards 
for the Bay. Protective Exhibit A 
standards in the Coordinated Operation 
Agreement are taken from the established 
Decision 1485 standards. 

Exhibit A standards in the Coordinated 
Operation Agreement require higher out- 
flow during dry and critical years than 
is required under the Tracy standards, 
and this higher outflow may indirectly 
protect the Bay. (See the general issue 
on Decision 1485 standards for further 
discussion of Exhibit A standards versus 
Tracy standards.) The Coordinated Oper- 
ation Agreement will assure this level 
of protection in the future, thereby 
guaranteeing increased outflows. Oper- 
ating both projects to meet these 
standards will commit 2.3 million acre- 
feet of firm project yield during a 
critical water supply period. Future 
standards updating those in Decision 
1485 may include protective standards 
for the Bay. Article 11 of the Agree- 
ment provides a method for new standards 
to be incorporated into the Agreement 
(see the general issues on Decision 1485 
standards and future standards). 

Although Decision 1485 did not establish 
specific outflow standards for San Fran- 
cisco Bay, the State Water Resources 
Control Board emphasized that considera- 
tion must be given to outflow needs of 
the Bay. The Board has developed 
interim policy guidelines regarding 
unregulated flows to be used in planning 
future projects. In an effort to 
advance knowledge of and protection 
for the Bay, investigations of the 



health and needs of the Bay are 
continuing. 

Studies for the Bay that include funding 
by the Department of Water Resources and 
the Bureau of Reclamation are part of 
the Interagency Ecological Studies 
Program. These studies are primarily 
outflow related; other investigations 
discussed later address toxics. The 
Interagency Ecological Studies are to 
answer questions on how operation of the 
State and Federal projects may relate to 
other factors and other water develop- 
ment to affect the Bay. Studies are 
underway to: 

Determine effects of changes in fresh- 
water flow on biota of San Francisco 
Bay, with emphasis on fish and shrimp 
populations. 

Determine effects of freshwater flow 
on estuarine hydrodynamics, including 
velocity distribution, mixing, 
particle transport, and salinity 
gradients . 

Determine effects of outflow-related 
changes in hydrodynanics on San 
Francisco Bay biota. 

Although no definitive conclusions have 
yet been reached from the interagency 
studies, understanding of some processes 
and relationships has advanced. A 
report that discusses this investigation 
is Effects of Freshwater Outflow on the 
San Francisco Bay , a joint report by the 
Department of Fish and Game, Department 
of Water Resources, U. S. Bureau of 
Reclamation, U. S. Geological Survey, 
U. S. Fish and Wildlife Service, and the 
State Water Resources Control Board. 
This report analyzes literature on estu- 
aries, including hydrology and toxology 
interrelationships. It contains a 
bibliography of over 100 reports related 
to this subject. Other reports that 
discuss the Bay include: 

San Francisco Bay: The Urbanized 
Estuary , T. J~. Conomos, Ed. (American 
Association for the Advancement of 
Science, 1979). 



23 



* San Francisco Bay: Use and 
Protection , W. J. Kockelman, 

T. J. Conomos, A. E. Leviton, Eds. 
(American Association for the 
Advancement of Science, 1982). 

* Toxicants in San Francisco Bay and 
Estuary , R. W. Risebrough, 

J. W. Chapman, R. K. Okazaki , 

T. T. Schmidt (Association of Bay 

Area Governments, 1978). 

* The Modification of an Estuary , 
F. H. Nichols, J. E. Cloern, 

S. N. Luoma, D. H. Peterson (Science, 
Vol. 231, 1986). 

In a March 1986 report by the Bay Area 
Dischargers Association by William J. 
(BJ) Miller, entitled The State of 
San Francisco Bay , historical trends in 
Bay water quality pollution patterns 
and key Bay fish and wildlife species 
abundance is reviewed. This report also 
discusses such issues as toxics, Delta 
outflow, and the possible effects of 
surface runoff on Bay water quality. 

The reports vary in presentation of 
material, and the following discussion 
is not a representative summary of those 
reports. Various topics of 
investigation for the Bay are discussed 
below. 

Circulation/Outflow . Bay circulation is 
driven by three main factors: tides, 
freshwater flow-induced estuarine 
circulation, and wind-induced mixing. 

Most water motion in the Bay is the 
result of tides. Filling and diking 
over the years have decreased the volume 
of the tidal prism (volume of water 
entering the Bay between low and high 
tide), which in turn has decreased tidal 
flushing of the Bay. The average volume 
of water passing the Golden Gate during 
a single flood or ebb tide is about 
1.1 million acre-feet, about 20 percent 
of the total volume of the Bay. About 
24 percent of this tidal prism (5 per- 
cent of Bay volume) is replaced by new 
ocean water during each tidal cycle. 



Estuarine circulation created by inflow 
from the Sacramento River system is also 
being studied as a factor affecting net 
transport into and out of the Bay. 
Estuarine circulation is driven by the 
difference in density between fresh 
water and salt water, which is related 
to Delta outflow. The importance of 
estuarine circulation and its associa- 
tion with the effect of winter storms on 
salinity distribution in the southern 
reaches of the Bay are being investi- 
gated in connection with flushing the 
South Bay. 

Delta outflow provides large amounts of 
suspended sediments and nutrients, which 
contribute to the ecological balance of 
the Bay. Drainage from Delta and valley 
agriculture is present in Delta 
out flow. 

Surface Runoff . The B. J. Miller 
report, The State of San Francisco Bay 
states that surface runoff in the San 
Francisco Bay basin is primarily due to 
rainfall. Surface runoff constitutes 
large quantities of suspended solids, 
heavy metals, and organics, which may 
affect organisms and habitat year 
round . 

Although in 1978 surface runoff 
represented less than 4 percent of the 
total inflow to San Francisco Bay, it 
accounted for an estimated 25 percent 
of the total suspended solids and over 
35 percent of the heavy metal input to 
the Bay. 

Identified adverse effects of surface 
runoff include bacterial pollution and 
shellfish contamination, and v^en stream 
runoff causes sewers to overflow, odor 
and other problems may also ensue. 

Toxics. The Citizens for a Better 
Environment Report, Toxics in the Bay: 
An Assessment of the Discharge of Toxic 
Pollutants to San Francisco Bay by 
Municipal and Industrial Point Sources 
(1983) states that industrial plants 
and sewage treatment plants annually 
discharge waste water containing about 



24 



11 million pounds of oil and grease and 
about 900,000 pounds of toxic pollutants 
into the Bay. 

Toxic pollutants to the Bay include 
heavy metals (cadmium, lead, zinc, 
chromium, copper, mercury, nickel, and 
silver), cyanides, arsenic, and organic 
chemicals (oil, phenols, solvents, pes- 
ticides, PCBs, and others). Properties 
of these substances that make them 
inherently hazardous in an estuarine 
environment include persistence and 
mobility in the environment, the ability 
to bioaccumulate and build to high con- 
centrations in the food web, and acute 
and chronic toxicity to estuarine 
organisms and wildlife. 

Bioaccuraulation of toxic pollutants has 
been detected in striped bass, in 
mussels and other shellfish, and in 
harbor seals taken from the Bay. Scien- 
tists at the National Marine Fisheries 
Service have studied a possible rela- 
tionship between adverse reproductive 
effects on striped bass and toxic pollu- 
tants present in striped bass tissue. 

Trends in Resource Levels . During the 
past century. Bay resources have been 
impacted by land reclamation, dredging, 
water development projects, water 
pollution, and over- fishing. Many of 
the commercial fisheries began to 
decline before the turn of the century. 

Primary declining resources in the Bay 
are the dungeness crab, striped bass, 
and white sturgeon. The crab decline 
was closely correlated with persistent 
changes in ocean conditions that began 
3 years before the initial decline. No 
single factor has surfaced as the major 
cause of the striped bass decline. 
Declining phytoplankton production. 
Delta water diversion projects, toxi- 
cants, and reduced egg production have 
been hypothesized as possible causes, 
singly or cumulatively. Fluctuating 
population levels of white sturgeon have 
been attributed to poor recruitment 
during the mid-1950s. Three causes of 



poor recruitment have been suggested : 
degradation of habitat for juveniles due 
to reduced freshwater flows , toxicant 
contamination, and declines in spawning 
stock size. 

Some resources are contaminated. Until 
recently, the Department of Health 
Services has not allowed shellfish to be 
harvested for human consumption due to 
contamination of the Bay shoreline by 
sewage and other material. Recent 
improvements in waste water discharges 
have allowed selected shellfish beds 
to be opened on a tempwrary basis. 

Although there have been decreases in 
some species several species have shown 
an increase in resource levels. Three 
of these are introduced species: the 
Korean shrimp, an important forage 
species; the Japanese littleneck clam, 
important in the diet of some sport 
fish; and the yellowfin goby, one of 
the most common species in the Bay and 
Delta. 

Although knowledge of factors regulating 
Bay resource levels continues to grow, 
considerable work remains. Such work 
is beyond the scope of the Coordinated 
Operation Agreement, as it pertains to 
the effects of meeting existing 
standards. As more knowledge is gained 
and as these standards change, including 
possible addition of Bay protective 
standards, vehicles exist that allow 
these new protective standards to be 
incorporated into the Agreement. 



Wetlands and Habitat 
in the Central Valley 

Issue 

The Coordinated Operation Agreement 
could foreclose opportunities to secure 
a firm supply of Central Valley Project 
water for Federal and State wetland 
areas in the Central Valley because it 
will provide for future water supply 
contracts . 



25 



Response 

Implementation of the Coordinated 
Operation Agreement will not prohibit 
allocation of Central Valley Project 
water supplies to wetlands. 

The Coordinated Operation Agreement does 
not obligate project water supplies to 
any use except Delta water quality and 
fish protection. Any future water 
supply contract requires action beyond 
this Agreement and must comply with the 
usual contracting and environmental 
review process. This is discussed in 
more detail in response to the general 
issue on future water marketing. 

Central Valley wetland areas and the 
habitat they provide for many wildlife 
species are indeed a significant 
resource of California and to the United 
States as a whole. The Bureau of 
Reclamation and the Department of Water 
Resources recognize the need for 
water supplies for Federal and State 
wildlife refuges in the Central Valley, 
The Coordinated Operation Agreement, 
however, is designed primarily to 
provide for more efficient operation of 
the Central Valley Project and the State 
Water Project to meet mandated water 
quality and fish protection standards in 
the Delta. 

Use of project supplies for fish and 
wildlife purposes is connected to 
project reauthorization, long-range 
studies, and agreements. 

In 1954, Public Law 83-674 reauthorized 
the Central Valley Project to provide 
water supplies for fish and wildlife. 
This reauthorization was subject to 
priorities applicable under other 
Central Valley Project authorization 
acts. In 1977, a Memorandum of the 
Regional Solicitor, Sacramento, to 
the Fish and Wildlife Service Field 
Supervisor concluded that the Central 
Valley Project was authorized by the 
1954 Act to provide water for fish and 
wildlife purposes under contract and 
subject to other priorities contained 



in the 1937 Central Valley Project 
authorizing act. 

The Central Valley Fish and Wildlife 
Management Study is investigating the 
water supply problems of the Central 
Valley wildlife refuges. The inter- 
agency team, which includes the U. S. 
Fish and Wildlife Service, is nearing 
completion of an appraisal-level study 
to identify problems and needs of the 
refuges. A 2-year planning study to 
identify sources of water and the best 
plan for the refuges will begin soon. 

In spring 1985, the Fish and Wildlife 
Service began a 2-year study to deter- 
mine the geographic extent and severity 
of agricultural drainage water contamin- 
ation of fish, wildlife, and their 
habitats in the Grasslands area. Water, 
sediments, plants, invertebrates, fish, 
birds, and small mammals are being 
sampled and analyzed to determine 
contaminant levels in Federal and State 
wildlife areas and private duck clubs. 
Waterfowl are being sampled during mid- 
and late summer, fall, midwinter, and 
early spring to determine: (1) levels 
of contaminants birds bring with them to 
wintering grounds; (2) levels they pick 
up during overwintering; and (3) levels 
they carry with them back to breeding 
areas. 

The Bureau of Reclamation recently 
agreed to a request by the Fish and 
Wildlife Service and Department of Fish 
and Game to furnish interim Central 
Valley Project water to wildlife refuge 
lands in the Grasslands area. This 
interim supply of fresh water will 
replace agricultural drainage water, 
which has been used, and will supplement 
the water supply to the wildlife areas. 

On November 6, 1985, the State Water 
Resources Control Board approved an 
urgency water right change to pump an 
additional 28,000 acre-feet of water 
from the Delta for use on publicly owned 
and managed wildlife lands in the 
Grasslands area until March 1, 1986. 
Agreement has been reached with the 



26 



Department of Water Resources to wheel 
the water and with the Fish and Wildlife 
Service and Department of Fish and Game 
to share the costs for wheeling. 



Area of Origin 



Issue 



The Coordinated Operation Agreement does 
not adhere to the California Watershed 
Protection Statutes because, under the 
proposed agreement, all Central Valley 
Project water users will be cut back by 
the same percentage during deficiencies. 
Exhibit E of the Agreement should 
provide a clear distinction between 
watershed users and non-watershed users 
and should preserve the priority in use 
for those in the watershed of origin. 



Response 

All negotiations and associated opera- 
tion studies to develop the provisions 
of the Coordinated Operation Agreement 
recognized the California Watershed 
Protection Statutes. 

Exhibit E does not apply to all Central 
Valley Project water users; it relates 
only to the contract for conveyance and 
purchase of Central Valley Project 
supplies by the State. Other Central 
Valley Project water supply contracts 
have different provisions or no provi- 
sions for deficiencies (such as the 
contract for Sacramento County) . In the 
future, any new contract for Central 
Valley Project water supplies will 
include deficiency provisions, and all 
contracts will be in accordance with 
applicable law. 

The Coordinated Operation Agreement is 
designed to avoid undue hardship to 
third parties (water users) . Both 
Article 2 and Article 18 of the Agree- 
ment state this intent. Article 2 
states that: 



"The United States and the State each 
plans to meet all requirements and 
objectives of its project and to 
coordinate the operation of their 
projects so as not to adversely affect 
the rights of other parties and to 
conserve water." 

Article 18 states: 

"Nothing in this Agreement is intended 
to define, determine, limit, or affect 
the rights of third parties." 

As discussed in Exhibit E of the Agree- 
ment, deficiencies in dry years will be 
imposed against all Central Valley 
Project water users at the same percent- 
age, unless prohibited by existing 
contracts , Central Valley Project 
authorizations, or a determination by 
the Contracting Officer that some other 
method of apportionment is required to 
prevent undue hardship. This provision 
does not interfere with existing 
contracts, and it allows for future 
contracts . 

Provisions in the Agreement also address 
the intent of both parties in connection 
with applicable statutory and decisional 
law in Article 11(d), which states: 

"The parties do not intend by this 
Agreement to confer any additional 
authority upon either the Secretary 
of the Interior or the State Water 
Resources Control Board beyond that 
derived from applicable statutory 
and decisional law". 



Seepage 



Issue 



Implementation of the Coordinated Opera- 
tion Agreement will increase seepage 
along the Sacramento River. This impact 
was not adequately addressed in the 
Draft Environmental Impact Statement/ 
Report . 



27 



Response 

Seepage impacts of the Cksordinated Oper- 
ation Agreement, discussed on pages 69 
to 77 of the draft report, were found 
not to be significant. Additional 
information is presented here to explain 
the basis for this finding. 

Seepage on agricultural lands along the 
Sacramento River has been a recurring 
problem since at least 1937. In some 
years, seepage of river water onto the 
lands adjacent to the river has damaged 
orchards and field crops. 

A 1983 dissertation* provides a thorough 
review of the seepage problem along the 
Sacramento River and lists other State, 
Federal, and university reports dealing 
with this issue. This report discusses 
project operations that act to minimize 
seepage problems along the Sacramento 
River. The report states that operation 
of Shasta Reservoir generally diminishes 
the downstream seepage potential, and 
that seepage potential is about 
80 percent of what would occur without 
upstream regulation. The report also 
suggests that, due to the geographic and 
temporal variation in seepage impacts, 
site-specific measures are more likely 
to be effective and economically 
justified than regionally-based 
solutions . 

In a study by the Department of Water 
Resources (Bulletin 125), effects of 
operating Oroville Reservoir were 
evaluated relative to seepage problems 
along the Feather and Sacramento rivers. 
This study concluded that operation of 
Oroville Reservoir should reduce the 
probability of seepage damage along the 
Feather River. Overall, large peak 
flood flows, which cause seepage prob- 
lems, should be reduced downstream of 
Oroville in the Feather and Sacramento 
rivers by reservoir operation. 



The State also recognizes the importance 
of minimizing seepage problems; these 
concerns are addressed in statutes of 
the California Water Code. Because of 
extensive seepage damage resulting from 
high flows during the spring of 1958, 
the Legislature added two sections 
concerning seepage. Section 12627.3 
established State policy that the costs 
of solving seepage problems arising from 
construction and operation of a water 
project will be borne by the project. 
Section 12627.4 directed the Department 
to contemplate seepage problems that may 
arise from future water projects and to 
include solutions as part of project 
development . 

The worst-case approach used in the 
draft report seepage analysis is 
designed to create the maximum differ- 
ence between no-project and the proposed 
action by holding the flow difference 
between Tracy standards and Exhibit A 
standards in storage in the no-project 
scenario. More likely operating 
assumptions would reduce or eliminate 
the differences, but would not necessar- 
ily represent a worst-case condition for 
impact evaluation purposes. 

The seepage problems occur during 
periods of high riverflows and on low 
elevation lands. Seepage-prone areas 
and critical river stages have been 
identified for various reaches of the 
river. The critical stages at which 
seepage begins in the various reaches 
are not exact, as different studies have 
identified different critical stages. 
Seepage usually occurs for several days 
or weeks. An approximation of increased 
seepage potential for the proposed 
agreement can be made using the draft 
report operation studies, which report 
monthly riverflow at various locations 
along the river. These studies 
investigated operating conditions of no 
action and the proposed action and 



*Priestaf, Iris Gail. Sacramento Seepage: 
Dissertation, U.C. Berkeley, May 1983. 



Alternative Mitigating Measures. Ph.D. 



28 



different levels of development. A 
riverflow station used to estimate 
potential seepage differences was below 
Red Bluff Diversion Dam. This point is 
actually upstream from the northernmost 
seepage-prone area; however, relative 
differences among the studies were made 
using that location. 

For both studies, increased seepage 
potential was identified during only a 
few months, because Exhibit A standards 
and Tracy standards only deviate during 
dry and critical years. In other years 
seepage may occur, but the potential is 
the same for both Tracy standards and 
Exhibit A standards. Following are 
discussions of relative differences for 
the 1980 and 2020 level of development 
operation studies. 

1980 Level of Development Study . 
Sacramento River flows at Vina Bridge 
were compared between the Exhibit A 
standards and Tracy standards for each 
month of the 1980-level study. 

In this study, an increased seepage 
potential was assumed if the monthly 
flow was about 1 million acre- feet or 
more in either the no-project or the 
proposed action conditions. This 
happens for only 3 months of the 
1980-level study, which investigated 
5 7 years, or 684 months. In 2 of these 
months, operation under the Coordinated 
Operation Agreement decreased seepage 
potential compared to the Tracy 
standards. In one month the Coordinated 
Operation Agreement standards slightly 
increased the seepage potential when 
compared to the Tracy standards. 

2020 Level of Development Study . By 
examining the 2020-level monthly flow 
differences between the Exhibit A 
standards and Tracy standards, it 
appears that seepage conditions changed 
during only six months of the 77-year 
study period, which included 924 months. 
In each of the six months, operating 
under Tracy standards caused more 
seepage potential than operating under 
Exhibit A standards. 



Southern Delta 



Issue 



The Environmental Impact Statement/ 
Report should correctly and adequately 
depict the potential impact of the 
Coordinated Operation Agreement on the 
southern Delta, particularly in rela- 
tion to the potential for worsening 
the loss of agricultural pump draft in 
some channels (such as occurred during 
1985). 



Response 

The current situation in the southern 
Delta is important, but signing the 
Coordinated Operation Agreement will 
not aggravate the pump draft problems. 
The Agreement assures that about 
2.3 million acre-feet of State and 
Federal project yield during a criti- 
cal water supply condition will be 
dedicated to Delta environmental and 
water supply protection and will be 
eliminated as a potential export 
source. In addition, the Coordinated 
Operation Agreement does not authorize 
any new contracts for water supplies 
that will require additonal exports. 
Any such contracts will require fur- 
ther environmental documentation and 
consideration of mitigation measures. 

Even though the southern Delta will 
not be impacted by the Coordinated 
Operation Agreement, the Department 
of Water Resources and the Bureau of 
Reclamation are working to solve 
the problems that now exist. On 
September 4, 1985, the Department and 
South Delta Water Agency signed a 
letter of intent to establish a 
program for ameliorating present water 
level and water circulation problems 
in the southern Delta. The letter is 
the first step toward a binding 
agreement . 

The most important part of the letter 
of intent establishes a cooperative 
planning program that envisions 



29 



construction of facilities in some 
channels and an additional inlet gate 
to Clifton Court Forebay as well as 
widening and deepening of some channels. 
The letter also provides procedures for 
cooperating to prevent or minimize 
irrigation pumping draft problems before 
the new plan can be put into effect. 
The letter of intent is a separate 
issue from coordinated operation of 
the Central Valley Project and the 
State Water Project. 

In January 1986, the Department of Water 
Resources prepared an Initial Study 
(under CEQA regulations) on a South 
Delta Agricultural Water Level 
Mitigation Project. The principal 
objective of the mitigation project is 
to improve the availability of water 
supply to existing irrigators in the 
Middle River and Tom Paine Slough areas 
pending a permanent solution. During 
the past few years, South Delta Water 
Agency has frequently expressed concern 
to the Department of Water Resources 
regarding low water levels in these 
areas caused by State, Federal, and 
other water development projects. 

The proposed mitigation project is 
designed to reduce or eliminate some 
adverse water level conditions in the 
southern Delta. This project consists 
of dredging in Tom Paine Slough, 
possible installation of siphons at the 
inlet to Tom Paine Slough, and 
installation and removal of a seasonal 
weir in Middle River near Victoria 
Canal. The project is designed to allow 
farmers v*io depend on these waterways to 
increase their pumping to levels at or 
above those that would exist without the 
State Water Project and the Central 
Valley Project . 



Recreation 



1 ssue 



Recreation should be a specifically 
authorized use of Central Valley Project 



water. Impacts to recreation in up- 
stream reservoirs were not sufficiently 
addressed in the Draft Environmental 
Impact Statement/Report. 



Response 

Although recreation is a significant 
use associated with Central Valley 
Project facilities, further authoriza- 
tion for recreational use of the Central 
Valley Project is beyond the scope and 
intent of the Coordinated Operation 
Agreement. Some components of the 
Central Valley Project have included 
authorization for recreation, including 
San Luis and New Melones reservoirs. 

The draft report evaluated potential 
impacts to recreation in upstream reser- 
voirs using hydrology studies to analyze 
the nature, extent, and frequency of 
drawdowns at each reservoir. Recreation 
impacts due to drawdown with and without 
the Coordinated Operation Agreement are 
shown on Table 14 (page 79) of the draft 
report. From information in this table, 
recreation impacts at Clair Engle, 
Whiskeytown, and Folsom reservoirs were 
judged to be not significant. A nominal 
change is shown for Shasta; this change 
includes a slight improvement and a 
slight adverse effect that tend to 
balance, for little change to annual 
recreation visits. 

Impacts of the Coordinated Operation 
Agreement on recreation were judged 
insignificant. However, more informa- 
tion is presented below in response to 
interest shown in letters commenting on 
this subject. This information shows 
that recreational use of Central Valley 
Project reservoirs has been extensive 
and that present problems and issues 
are not related to the Coordinated 
Operation Agreement. 

An investigation of recreation at 
Shasta, Clair Engle-Lewiston , Whiskey- 
town, Folsom, Natoraa, and Auburn 
reservoirs is summarized in the Draft 



30 



Environmental Statement on the Reauthor- 
ization of the CVP and the Coordinated 
Operation Agreement for CVP-SWP (1980). 
This report showed the nature of recrea- 
tion, successful efforts to improve 
recreation, and the complex interrelated 
factors that affect recreation. Central 
Valley Project reservoirs and other 
features provide recreational opportuni- 
ties for almost 10 million visitor-days 
of use per year. Managing agencies of 
each reservoir area were asked to 
provide information about existing and 
proposed facilities, carrying capacity 
constraints of facilities, scope and 
extent of recreation activities, speci- 
fic factors that limit recreation at 
each lake, and optimim use based on 
capacities of facilities developed by 
the year 2020 (for Auburn and Folsom, 
2000 was used to be consistent with 
recent master plans). 



Levees and Cross-Delta Flows 

Issue 

Impacts from increased cross-Delta flows 
on levees have not been adequately 
addressed in the Environmental Impact 
Statement/Report , 



Response 

Operation of the Delta Cross Channel 
has caused continuing impacts on the 
channels of the Mokelumne River. The 
situation will exist with or without the 
Coordinated Operation Agreement, and 
the Agreement will not aggravate the 
problem. Analysis shows that cross- 
Delta flows under the Coordinated 
Operation Agreement will remain within 
the range that has existed since project 
operation. 

The Department of Water Resources is 
discussing this issue with North Delta 
Water Agency, the reclamation districts, 
and landowners and will seek cooperation 
of the Bureau of Reclamation in 
analyzing and solving existing problems. 



A letter dated July 19, 1984, from the 
Director of Water Resources to the 
Manager of North Delta Water Agency 
stated the Department's commitment to 
resolving this issue. The remainder of 
this response is a duplication of the 
Director's letter. 

"The Department recognizes that there 
have been continuing impacts upon the 
channels of the Mokelumne River caused 
by the federal cross channel through 
which water of the federal Central 
Valley Project and some water of the 
State Water Project now flows. The 
Department of Water Resources will 
attempt to address this issue in 
consultation with the Agency, 
Reclamation Districts and landowners 
and seek the cooperation of the United 
States Bureau of Reclamation in the 
analysis and solution of existing 
problems. 

"The Department of Water Resources is 
also aware of Delta landowner concerns 
that in proceeding with a State proj- 
ect we would attempt to limit our 
responsiblity for erosion control to 
only those areas of actual construc- 
tion as has been the history of the 
federal cross channel. This is not 
the case. We intend to analyze and 
examine conditions in the Delta to be 
sure we do not cause flow changes that 
could be reasonably considered to 
cause measurable adverse impacts 
without mitigating such impacts. 

"It is recognized that existing 
preliminary design information may be 
insufficient to accurately project 
velocities and stages of channel 
flows. However, as detailed design 
and construction proceeds, the 
Department will prevent or correct 
erosion or seepage problems 
attributable to the project. Should 
operational experience of completed 
works reveal unforeseen impacts 
attributable to Department of Water 
Resources actions, they will be 
corrected . 



31 



"The contract between the State and 
the North Delta Water Agency dated 
January 28, 1981, provides in 
Article 6 for the repair or allevia- 
tion of any erosion or water level 
impacts caused by the State Water 
Project upon users within the Agency. 
I concur that a supplemental agreement 
with the Agency should be agreed upon 
prior to construction of channel work 
in the North Delta envisioned in 
Senate Bill 1369 to implement this 
contract provision, existing Water 
Code sections 12627,3, 12627.4 and 
section 12627.5 proposed for Senate 
Bill 1369. 

"The supplemental agreement between 
the State and the Agency, and the 
State's commitment to Reclamation 
Districts and landowners abutting 
effecting channels, will cover at 
least the following points: 

"(a) Designation of an employee by 
Department of Water Resources to be 
responsible for liaison with the 
Agency, Reclamation Districts and 
landowners . 

"(b) Appointment by the Agency of an 
advisory committee to the Department 
on such matters as the selection of 
project design criteria, construction 
specifications, alignment, and 
right-of-way requirements. This would 
include recreational features. 



Friant and New Melones Projects 
Issue 

An explanation should be provided as to 
why water diversion facilities on the 
San Joaquin River, such as Friant and 
New Melones dams, are not governed by 
this Agreement and why they are not 
expected to contribute to Bay-Delta 
water quality control. Also, New 
Melones should be included to provide a 
potential benefit to the Central Valley 
Project's power production. 



Response 

The Coordinated Operation Agreement 
defines specific project withdrawals 
to provide for established quality 
protection for the Delta. These with- 
drawals are based on Delta outflow 
needs, and, to the extent upstream proj- 
ects such as Friant and New Melones 
alter Delta inflow, this change must be 
compensated by other reservoirs. Stor- 
age withdrawals v^re designed to be a 
function of integrated State and Federal 
project operations to meet total Delta 
needs, rather than a function of indivi- 
dual reservoir releases to meet specific 
proportions of outflow needs. This 
design provides flexibility benefits for 
coordination and operation of the State 
Water Project and Central Valley 
Project . 



"(c) Provision to the Agency by 
Department of Water Resources of all 
applicable records and files relevant 
to and indicative of flows and seepage 
from the channels in the North Delta. 
This information will be made 
available prior to the agreement if 
requested by Agency. 

"(d) Provision for detailing 
maintenance standards and appropriate 
sharing of financial responsibility 
for maintenance among the Department 
and Reclamation Districts." 



Providing the greatest flexibility for 
coordination and operation of the State 
Water Project and the Central Valley 
Project was a major goal in formulating 
the Coordinated Operation Agreement. 
Provisions were designed for both 
projects to fairly share in meeting 
established Delta protective measures, 
protecting the financial integrity of 
the projects, and continuing to meet 
project responsibilities including power 
and water supply. This required a 
careful look at all facilities of both 
projects and selection of optimal 
operational criteria. 



32 



Even though Friant Dam (Millerton Lake) 
and New Melones Dam projects are not 
included in Article 3 of the Agreement, 
which pertains to storage withdrawals, 
they are included in Article 5, which 
lists existing project facilities 
integrated into operation studies used 
to develop and confirm governing 
provisions of the Agreement. Including 
these projects in the operation does 
influence storage withdrawal amounts. 
In addition. New Melones and Friant are 
operated in accordance with authorized 
priorities. New Melones priorities 
include flood protection, municipal and 
industrial water supply, power, fishery 
enhancement, and water quality. 
Reservoir releases for fish and water 
quality are governed by regulation 
separate from the Coordinated Operation 
Agreement and represent contributions to 
the estuary in addition to the 
Agreement. Both Friant and New Melones 
are operated to optimize power in 
accordance with authorized priorities, 
and this operation will continue. 
Friant does not produce any Federal 
power; the local districts operate the 
power plants. Power is only incidental 
to other authorized purposes. 

To evaluate and finalize the Agreement 
provisions, the existing project facili- 
ties identified in Article 5 and the 
project water supplies from Exhibit B-1 
and B-2 were used to complete detailed 
project operation studies. The method- 
ology used is described in the Technical 
Report on the Determination of Annual 
Water Supplies for the Central Valley 
Project and State Water Project. This 
report is cited in Article 6 of the 
Agreemeot and is included as Appendix G 
of the draft report. 

The operation studies evaluated project 
operations to meet Delta protective 
criteria, to provide flows for instream 
needs, to meet project water supply 
deliveries, and to provide power. 
Operations were investigated for a 
sequence of historical years, but with 
the hydrology adjusted to reflect the 
level of development to be studied. 
This adjustment process accounts for 



both Friant and New Melones projects and 
computes total needed project releases. 
This adjustment divides the Central 
Valley into 40 subareas, including all 
the basins tributary to the Delta. For 
each subarea, adjustments included area 
inflow and outflow, imports and exports, 
consumptive use by developed areas, and 
any modifications due to regulating 
facilities such as reservoirs. 

This adjusted hydrology includes the 
effects of the Friant and New Melones 
projects on the San Joaquin River, which 
is tributary to the Delta and, there- 
fore, directly affects the magnitude of 
required storage withdrawals. Even 
though these reservoirs were integrated 
into project operations to define 
storage withdrawals, the adjustments 
showed that, due to the magnitude of 
prior in-basin commitments, neither 
facility will have the necessary long- 
term storage flexibility to help meet 
withdrawal requirements in Article 3 of 
the Agreement. Each facility, on 
occasion, makes releases that do add to 
the unregulated flow available for 
export and water quality in the Delta. 
However, during balanced water condi- 
tions, when the sharing formula of the 
Agreement would be in effect, water is 
fully committed for in-basin use under 
the ultimate level of development for 
both facilities. 

On an interim basis, some supplies from 
New Melones may not be fully used. To 
the extent these supplies provide 
unregulated or regulated inflow to the 
Delta by increasing San Joaquin River 
flows, this will benefit the estuary. 

In the future as the amount of New 
Melones supplies that provide inflow to 
the Delta on an interim basis is better 
defined, it can be incorporated into the 
joint periodic review of the agreement 
according to Article 14. This article 
calls for review of operation studies 
supporting this Agreement. This review 
can result in adjustments to account for 
the influence that this potential 
interim Delta inflow has on project 
responsibilities to meet Delta needs. 



33 



Section 2 



CORRECTIONS AND ADDITIONS 



This section updates the text and 
appendixes of the draft report to the 
Final Environmental Impact Statement/ 
Report for the Coordinated Operation 
Agreement, Changes and updates result, 
in part, from comments obtained during 
the public review period. All written 
comments and verbal testimony received 
on the draft report were reviewed in 
detail and acted on, using one or more 
of the following: 

Incorporation into general issue 
response (see Section 1); 

Change to the draft report by correc- 
tion or addition, as presented in this 
section; 

Acknowledgement of comment by repro- 
duction of the comment letter or 
testimony by publication in 
Section 3. 

A special case was the Fish and Wildlife 
Service Coordination Act Report on the 
Coordinated Operation Agreement. This 
report, along with responses by the 
Bureau of Reclamation, is included in 
this section. The responses by the 
Bureau also represent the response to 
the Department of Fish and Game's 
comments recommending mitigation 
measures. 



the annual purchase of interim and 
intermittent CVP water by the SWP, 
which can be recalled by the CVP when 
needed by existing or new long-term 
CVP contractors. 



Page S-3 , left column, paragraph 3 

Reword the paragraph as follows: 

The Agreement protects the interests 
of both projects \*iile improving the 
level of protection afforded the 
water-related environment of the 
Sacramento-San Joaquin Delta. 



Page S-6 , partial paragraph top of 
left paragraph 

Change 143,000 acre- feet to 152,000 
acre- feet . 



Page S-6, right column, paragraph 1 

Reword the second sentence as follows: 

Critical years occur less than 
10 percent of the time, and operations 
during other year types would have 
smaller or no change to significantly 
affect storage. 



Page S-2 , right column, paragraph 3 

Change 8.4 MAF to about 8.3 MAF. 
Change 3.6 MAF to 3.7 MAF. 



Page S-3, left column, paragraph 1 

Change the first sentence as follows: 

Section 10(h) calls for a contract to 
be concluded by December 31, 1988, for 



Page S-7 , right column, paragraph 1 

Delete the last sentence and substitute 
the following: 

Under wDrst-case operating conditions, 
the potential for temperature change 
exists at upstream locations below 
Central Valley Project reservoirs. 
Frequency and magnitude of f>otential 
impacts to salmon were investigated 
and judged not to be significant. It 



35 



was determined that the Proposed 
Action provided many protective flows 
for salmon above No Action in the 
Delta. 



Page S-8 , partial paragraph top of 
left column 

Delete the second sentence and replace 
with the following: 

Terras of the moratorium provide that 
it would be lifted when the Bureau 
committed itself to meet State Delta 
water quality standards incorporated 
into a coordinated operation agree- 
ment, the issue of instrean flow needs 
have been resolved, and the water 
needs for migratory birds on Central 
Valley National Wildlife Refuges have 
been met. There is an uncommitted 
water supply of the CVP of about 
1 million acre-feet annually. When 
the Coordinated Operation Agreement is 
signed, the Bureau of Reclamation will 
commit itself to the standards set 
forth in Exhibit A. 

A number of studies are investigating 
instream flow needs for fish on the 
Sacramento, American, and Trinity 
rivers and Clear Creek. The Bureau of 
Reclamation is also studying the water 
needs of the wildlife refuges. 
Results of the above studies for fish 
and wildlife needs will be incorpo- 
rated into the marketing program for 
the uncommitted supply of CVP water. 



Page S-8, left column, paragraph 1 

Delete and replace with the following: 

The Bureau of Reclamation will be 
studying the marketing of water to the 
service areas of the CVP. Any future 
contracts would require new contrac- 
tual agreements separate from the 
Coordinated Operation Agreement and 
must provide environmental documenta- 
tion as required by law. 



Page S-9. Table S-1 

Change 143,000 acre-feet to 152,000 
acre- feet . 

Delete the first footnote and substitute 
the following: 

No incremental impacts between the 
No Action alternative and Proposed 
alternative were judged to be signifi- 
cant based on CEQA criteria listed in 
Appendix K. 



Page 8, left column, paragraph 3 

Delete paragraph and replace with the 
following : 

In-basin needs projected by operation 
studies consist of Delta needs and 
Sacramento Valley needs upstream of 
the Delta. Sufficient water is 
released by reservoirs to assure that 
both the Delta and upstream in-basin 
needs are met. This is verified in 
the Delta by monitoring to ensure 
compliance with Delta water quality 
standards and flow requirements 
contained in Exhibit A. 



Page 12, partial paragraph, top of 
right column 

Add the following paragraph after the 
partial paragraph: 

Although the Agreement specifies 
April 30 as the final day for makeup 
wheeling, a letter received by the 
Department of Water Resources and 
Bureau of Reclamation from the State 
Water Resources Control Board states 
that March 31 is the final date. Any 
inconsistency between the letter and 
the Agreement is being reviewed and 
will be resolved with the State Water 
Resources Control Board. 



36 



Page 22, partial paragraph, top of 
right column 

Reword the sentence as follows: 

Current Bureau policy is an interim 
policy designed to operate to meet the 
Decision 1485 standards in ordinary 
critical years and to consider not 
meeting these standards only in years 
such as 1977, the driest year of 
record. 



Page 25, left column, paragraph 3 

Change the revised standards from 1988 
to 1989. 



Page 26, left column, paragraph 3 

Delete the last sentence and substitute 
the following: 

The Fish and Wildlife Service proposal 
was not accepted by the negotiating 
team of the Coordinated Operation 
Agreement . 



Page 28, left column, paragraph 2 
Delete the second sentence. 
Page 34, left column, paragraph 2 
Change 2,273,000 to 2,274,000. 

Page 34, left column, paragraph 4 
Change 983,000 to 982,000. 

Page 34, Table 4 

Change the following: 

+1,118 to +1,188 
-2,273 to -2,274 
-1,071 to 1,072 
-983** to -982** 



"** about 143,000 acre- feet" to 
"** about 152,000 acre-feet". 



Page 34, partial paragraph, top of 
right column 

Change 143,000 to 152,000. 



Page 36, right column, paragraph 2 

Change about 140,000 acre-feet to 
152,000 acre- feet . 



Page 37, left column, paragraph 1 

If both projects are operated in a 
manner that assures realization of the 
No-Action Case A scenario in critical 
years, firm annual water supplies at the 
1980 level of development increase by 
about 113,000 acre- feet for the CVP 
and about 178,000 acre-feet for the 
SWP. 



Page 37, Mitigation Measures 

Delete paragraph and replace with the 
following : 

The Agreement provides an overall 
improvement of resource level 
protection. The Exhibit A standards 
of the Proposed Action are mitigation 
for the projects. There is no 
proposed mitigation for the Proposed 
Action beyond the Exhibit A 
standards. 

Under worst-case operating conditions, 
the potential for temperature change 
exists at upstream locations below 
Central Valley Project reservoirs. 
The frequency and magnitude of 
potential impacts to salmon were 
investigated and judged not to be 
significant. It was determined that 
the Proposed Action provided many 
protective flows for salmon above No 
Action in the Delta. 



37 



Temperature control for fish protec- 
tion in the Sacramento and Trinity 
rivers is an important concern in 
operation of the Central Valley 
Project and is the subject of ongoing 
studies. Further studies and actions 
are reviewing various protective 
measures for this concern separate 
from this proposed action. 

The Bureau of Reclamation evaluated 
multilevel outlets for Trinity and 
Shasta dams. The Trinity Dam study is 
complete, however, the ability of 
multilevel outlets to mitigate Coordi- 
nated Operation Agreement impacts was 
not evaluated. The feasibility of 
multilevel outlets at Shasta Dam for 
controlling Sacramento River tempera- 
tures is being evaluated in the Cen- 
tral Valley Fish and Wildlife Manage- 
ment Study scheduled for completion 
during 1986. Benefits appear to be 
marginal in most years and even less 
effective in critical years when cold 
water availability in Shasta Lake is 
depleted during severe drawdown. 

Another measure to increase the survi- 
val rate of fish involved construction 
of a temperature control curtain at 
Lewiston Lake and special project 
operations during critical periods of 
temperature increase. The curtain 
allows warmer surface water to be 
skimmed and channeled into the incu- 
bators and rearing ponds at Trinity 
River Fish Hatchery. An increase in 
temperature of one or two degrees 
greatly benefits the growth of young 
fish. The rate of return of steelhead 
has increased since the curtain was 
installed . 

Special operations to improve the 
water temperature and flow situation 
have occurred in the past. The Bureau 
of Reclamation and the Department of 
Water Resources cooperated in altering 
operations at Shasta, Trinity, Folsom, 
and Oroville reservoirs to provide the 



best available water temperatures and 
to stabilize flow releases during the 
spawning period in the 1976-1977 
drought. Water temperatures were 
reduced on the Sacramento River by 
using cooler Trinity-Whiskeytown water 
with a corresponding decrease in 
releases from warmer Shasta Reservoir. 
American River temperatures were 
lowered by using the Folsom Dam low 
level outlet near river elevation. 
This operation was at the expense of 
some power production. The Coordi- 
nated Operation Agreement improves the 
ability for both projects to better 
use existing supplies and to provide 
this type of special operation. 



Page 38, Table 5 

Change 143,000 acre-feet to 152,000 
acre- feet . 



Page 39, left column, paragraph 3 

Reword the sentence as follows: 

The Proposed Action and No Action are 
considered within the context of the 
State of California, the Central 
Valley Basin, Trinity River Basin, and 
the two largest water development 
projects in that basin: the Central 
Valley Project and the State Water 
Project . 

Page 49, left column, paragraph 2 

Replace the first sentence as follows : 

Under Decision 1485, chloride content 
of the water at either Rock Slough or 
Antioch Water Works intake on the San 
Joaquin River is required to be 
150 ppm or less for a minimum of 
155 days per year, and Rock Slough may 
not exceed a maximum mean daily value 
of 250 ppm at any time. 



38 



Page 49, left column, paragraph 3 

Replace the first sentence as follows: 

Usable water is available for direct 
diversion in the Antioch-Pittsburg 
area for varying amounts of time, 
depending on prevailing hydrology. 



Page 55, right column, partial 
paragraph 1 

Add the following: 

If the termination provisions in 
Article 10(h)(5) of the Coordinated 
Operation Agreement were implemented, 
actual operations would not be worse 
than the No Action alternative. 
Historical operations have shown that 
the Bureau of Reclamation has operated 
the CVP to meet Delta requirements. 



Page 64, right column, paragraph 1 

Change 7.32 million acre-feet to about 
7.17 million acre- feet. 



Page 64, left column, paragraph 2 

In two places change 143,000 acre-feet 
to 152,000 acre- feet. 



Page 66 , Table 9 

Change the table as follows: 

Sacramento Valley : Change losses to 
49,000 and subtotal to 3,147,821. 
Change Total from 7,132,922 to 
7,189,622. 

Delta : Change San Felipe Unit to 
216,000 and subtotal to 3,207,601. 



Page 58, right column, last paragraph 

Delte the paragraph and replace with the 
following : 

Flow in Delta Channels. Operating 
the CVP and the SWP to the Tracy 
standards in critical years would 
increase the frequency and magnitude 
of reverse flows in the lower San 
Joaquin River in April, causing an 
increase in the number of striped 
bass from the Sacramento River that 
would be drawn to the export pumps. 
Also, flows in the Sacramento River 
would decrease in April, May, and 
June compared to operation for the 
Exhibit A standards, further reducing 
the survival of striped bass migrat- 
ing down the river. 



Page 62, partial paragraph, top of 
right column 

Change 143,000 acre- feet to 152,000 
acre- feet . 



Page 71 , left column, paragraph 2 

Add the following sentence: 

The Trinity River below Lewiston Dam 
is a component of the National and 
State of California Wild and Scenic 
Rivers systems. 

Page 73, left column, paragraph 2 

Add the following sentence: 

The American River below Nimbus Dam is 
a component of the National and State 
of California Wild and Scenic Rivers 
systems . 

Page 73, right column, last paragraph 

Reword the second sentence as follows: 

The differences would arise princi- 
pally in critical years and with 
lesser effect in the year(s) immedi- 
ately following critical years. 



39 



P age 74, partial paragraph, top of 
left column 

Add the following sentence: 

The Proposed Action was judged consis- 
tent with both State and Federal Acts 
concerning wild and scenic rivers. 



Page 80, right column, paragraph 2 

Add the following paragraphs after the 
second paragraph: 

Operation of Folsora Lake with the 
Coordinated Operation Agreement is not 
expected to require pumping from any 
lower level than has been planned for 
the reservoir in the absence of the 
Coordinated Operation Agreement. 
However, because the Coordinated 
Operation Agreement permits operation 
of the CVP to meet its full potential 
of benefit, the project reservoirs 
will be drawn down to their lower 
operating levels more often, but not 
lower than originally contemplated. 
In the absence of the Coordinated 
Operation Agreement this could have 
been the situation anyway, because 
project power operations will also 
draw down the reservoirs in many 
years. 

The No Action scenario used in this 
report, wherein Delta water quality 
standards were relaxed to Tracy 
criteria in critical years, resulted 
in higher levels in Folsom Lake simply 
due to the assumptions used in that 
study. These assumptions were 
primarily to evaluate worst-case 
conditions and are not representative 
of future operating conditions. The 
study assumed existing facilities, 
which limited the use of CVP firm 
yield. In the case of the No Action 
scenario, a portion of the conserved 
CVP supplies available by not meeting 
Delta standards were stored in Folsom. 
This operation assumes that stored 
supplies would be left in reservoirs 



during critical water supply periods 
when statewide shortages exist. It is 
likely, however, that in actual opera- 
tions, Folsora will be drawn down to 
the same low levels in critical years 
under any scenario. It is the easiest 
CVP storage facility to refill, due to 
its high ratio of average runoff to 
active storage. The operation study 
used to evaluate the Coordinated 
Operation Agreement is just one of 
many ways the project could be oper- 
ated to meet its objectives. Based on 
the probable infrequent occurrence of 
the worst-case condition and the fact 
that minimum drawdown levels will not 
change, no mitigation is proposed. 



Page 83, left column, first paragraph 
Delete second sentence. 



Page 88, right column 

Insert the following paragraph after the 
paragraph beginning "Final design...: 

The work program for the western Delta 
overland facilities consists of three 
phases: Phase I is a feasibility 
study and environmental documentation. 
Phase II will be design, and Phase III 
will be construction if warranted by 
Phase I findings. An agreement 
between Reclamation District 341 and 
the Department of Water Resources for 
a portion of Phase I work has been 
drafted. This agreement specifies 
that the Department will pay up to 
$300,000 for a feasibility study and 
documentation of environmental impacts 
that may occur on Sherman Island. 
If the agreement is approved , an 
engineering consulting firm will be 
selected to perform the work. 



Page 91 , right column, paragraph 2 

Replace the second sentence with the 
following : 



40 



From the reservoir, water will flow 
through the 1.8-mile existing section 
of Pacheco Tunnel and be lifted by 
Pacheco Pumping Plant to the 5.3-mile 
Pacheco Tunnel Reach 2. From the 
tunnel, water will be conveyed by 
gravity through pipelines to the 
terminal facilities in Santa Clara 
County and the San Justo Reservoir 
in San Benito County. 



The Bureau is studying water supply 
needs for Federal and State wildlife 
refuges in the Central Valley as part 
of the Central Valley Fish and 
Wildlife Management Study. A 2-year 
planning study on water needs has 
begun that will identify sources of 
water and methods to deliver a firm 
supply of water of acceptble quality 
to the refuges and the Grasslands. 



Page 97, right column, paragraph 4 

Delete the third sentence and replace 
with the following: 

The terms of the moratorium provided 
that it would be lifted when the 
responsibilities of the CVP toward 
water quality protection in the Delta 
had been clarified and the Bureau had 
committed itself to meet these and 
other responsibilities. The Bureau 
intends to resume entering into 
long-term water service contracts once 
the Coordinated Operation Agreement is 
signed and other requirements are 
completed. Regarding these 
requirements, the Bureau is doing the 
following. 



Page 97, right column, paragraph 4 

Add the following: 

A number of studies are addressing 
instream flow needs. Increased 
minimum flows in the Trinity and 
American rivers were discussed in the 
section on Other Projects and Actions, 
A portion of the Central Valley Fish 
and Wildlife Management Study is 
studying salmon spawning and the 
benefits and costs of increased flows 
in Clear Creek. Another portion of 
that study is evaluating several 
alternative flow regimes for salmon 
in the Sacramento River. 



Page 97, right column, last paragraph 
Delete paragraph. 

Page 98, partial paragraph, top of 
left column 

Delete paragraph. 

Page 98, left column, paragraph 1 

Insert new paragraph: 

The Bureau will be preparing environ- 
mental impact statements for future 
water marketing for the Central Valley 
Project. The marketing program to be 
undertaken will not be completed for 
some time. However, studies on fish 
and waterfowl needs should be com- 
pleted before completion of the water 
marketing program. Efforts to meet 
all water needs will be considered 
part of the marketing action separate 
from the Coordinated Operation 
Agreement . 

Appendix A, page 7 

Add San Justo Reservoir to the 
facilities of the United States. 

Appendix C, page 3, paragraph 2 
Change last sentence as follows: 



41 



Some of the concerns of the Fish and 
Wildlife Service are as follows: 



Appendix C, pages 3-9 

Change Recommendation No. 1 through 
Recommendation No. 5 to Concern No. 1 
through Concern No. 5. 



Appendix G, page 6 

Add the following paragraphs: 

The Bureau of Reclamation has on 
several occasions reevaluated the 
water needs of various service areas, 
including the Tehama-Colusa Canal 
service area. Reevaluation of water 
requirements is desirable and neces- 
sary for several reasons, including: 
changing agricultural economics, as 
reflected through projected cropping 
patterns; increasing availability of 
empirical data on crop water require- 
ments; and integration of water 
conservation measures. 

In general, empirical data gathered 
from districts in the Sacramento 
Valley demonstrate significantly 
smaller per- acre- foot water require- 



ments than those previously projected 
through use of mathematical models. 
Required conservation measures will 
continue to necessitate more efficient 
delivery systems and higher tailwater 
recapture percentages. In accordance 
with requirements of the Reclamation 
Reform Act of 1982 and California 
State water conservation programs, 
the Mid-Pacific Region will require 
prudent use of available nonproject 
resources, including ground water. In 
general, these considerations result 
in a reduction of the estimated 
project water needs of a given service 
area. 

It is the Bureau of Reclamation' s 
responsibility to ensure efficient use 
of a valuable resource and thereby 
prevent overallocation of water to a 
given contractor or service area. 
Occasional reevaluation of future 
water needs of contractors requesting 
new or additional project entitlements 
greatly assists the Bureau in meeting 
this planning objective. Such a 
practice reduces the probability of 
economic hardship upon a district 
constructing and operating a distribu- 
tion system or potentially unable to 
pay for a full contracted supply 
without undue financial burden. 



42 




UNITED STATES DEPARTMENT OF THE INTERIOR 

FISH AND WILDLIFE SERVICE 




CVP/SWP COORDINATED 
OPERATION AGREEMENT 

CALIFORNIA 




A DETAILED REPORT ON 



FISH AND WILDLIFE RESOURCES 



REGION ONE 




United States Department of the Interior 

nSH AND WILDLIFE SERVICE 
Lloyd 500 BuUding, Suite 1692 
500 N.E. Multnomah Street 
Portland, Oregon 97232 



N0V26I985 



Memorandum 

To ; Regional Director, Mid-Pacific Region, Bureau of Reclamation 

Sacramento, California 

From : Regional Director, Region 1, Fish and Wildlife Service 
Portland, Oregon 

Subject : Fish and Wildlife Coordination Act Report on the Coordinated 
Operation Agreement 



This memorandum, with the attached detailed assessment, constitutes our Coor- 
dination Act report of the effects on fish and wildlife resources of implementing 
the "Proposed Agreement between the United States of America and the Depart- 
ment of Water Resources of the State of California for Coordinated Operation of 
the Central Valley Project and the State Water Project." The proposed agreement, 
dated May 20, 1985, and commonly referred to as the Coordinated Operation 
Agreement, or COA, would make possible more efficient operation of the Federal 
Central Valley Project (CVP) and the State Water Project (SWP). AdditionaUy, 
under terms of the COA the Bureau of Reclamation would be obligated to operate 
the CVP to meet the water quality standards for protection of the Sacramento-San 
Joaquin Delta set by the State Water Resources Control Board in Decision 1485. 

Our analysis is based on information provided by the Bureau of Reclamation prior 
to June 1, 1985 —including the draft COA; operation studies at 1980 and 2020 
levels of development under Tracy (in dry and critically dry years only) and D-1485 
water quality standards; and the internal review draft Environmental Impact 
Statement/Environmental Impact Report on the COA, dated May 21, 1985. This 
analysis is valid only for the draft COA of May 20, 1985. In the event that the 
draft COA is modified a revision of this report may be necessary. 

This report was prepared under authority, and in accordance with the provisions, of 
the Fish and Wildlife Coordination Act (16 U.S.C.661 et seq.) and is intended for 
inclusion in the Bureau of Reclamation's report on the proposed action. This report 
has been reviewed and commented on by the California Department of Fish and 
Game as indicated by the attached copy of a letter from Director Jack C. Pamell, 
dated October 17, 1985. Also, it has been reviewed and concurred in by the 
National Marine Fisheries Service; their letter is attached for your information. 



45 



Considering the importance of the fish and wUdlife resources that would be 
affected by the proposed action, this report, required for your compliance with the 
Fish and Wildlife Coordination Act, is inappropriately brief and unsupported by 
field studies as normaUy required for evaluating a proposed action of this 
significance. Time allowed for report preparation was too short due to the brief 
period between completion of the draft COA and its being taken up by the 
Congress for action. As such, our recommendations to mitigate the impacts of the 
proposed action are not reflected in the draft COA as they normally might have 
b^en. The recommendations should not, however, be wholly unexpected on your 
part since they are consistent with input to your draft environmental statement 
which was provided to you in December 1983. 

The COA would affect habitat for fish and wildlife resources in (1) the 
Sacramento-San Joaquin Delta — its waterways, agricultural lands, and Suisun 
Marsh, (2) the Central Valley — especially CVP/SWP-controUed rivers and reser- 
voirs, and CVP/SWP water service areas, (3) the San Francisco Bay system 
upstream to the western boundary of the Delta, and (4) the Trinity River basin — 
principally Clair Engle and Lewiston Lakes and reaches of the Trinity River. 

Based on our analysis, we conclude that implementation of the COA would 
beneficially impact striped bass and Chinook salmon habitat in the Sacramento-San 
Joaquin Delta and waterfowl habitat in Suisun Marsh but adversely impact fish and 
wildlife habitat in the Federal and State water service areas, in San Francisco Bay, 
and in the Sacramento, American and Trinity Rivers. While we are pleased that 
better water conditions would exist for fish and wildlife in the Delta, our foremost 
concern is that the COA would (1) exacerbate temperature problems in the 
Sacramento, Americsm and Trinity Rivers affecting salmon spawning and egg 
incubation, and (2) perhaps reduce opportunities to secure a firm supply of CVP 
water for Federsil and State wetland areas in the Central Valley, and meet 
unidentified/unmet mitigation needs of past constructed units of the CVP. Salmon 
threatening increases in water temperature downstream from Shasta, Folsom and 
Clair Engle Reservoirs would result from COA-induced changes in reservoir storage 
levels and release volumes. During and immediately following critically dry years 
severe decimation of salmon runs would be highly likely and extirpation of the 
winter-run race of salmon in the Sacramento River is not inconceivable. For 
maintenance of wintering habitat in the Central Valley for Pacific Flyway 
waterfowl populations, it is essential that a firm supply of CVP water be provided 
to nine wildlife refuges and two wetland easement areas administered under the 
National Wildlife Refuge System, and to three wildlife management areas adminis- 
tered by the California Department of Fish and Game. This need should be met 
before the uncommitted firm yield of the CVP, some of which is made possible by 
the COA, is committed to other uses. The Department of Interior's position on 
authority to commit CVP firm supply for waterfowl purposes is presently unclear 
but I understand that clarification may be forthcoming. Further, CVP power should 
be provided on a non-reimbursable basis to the nine national wildlife refuges, four 
State waterfowl management areas, and to Coleman National Fish Hatchery. 

We must also note that there are known deficiencies in the D-1485 standards that 
preclude protection of Delta fish habitat at the desired level; habitat necessary for 
estuarine fish as well as upriver-spawning species which migrate thru the Delta. 
D-1485 standards may be inadequate for striped bass. Since 1978 the recruitment 
of striped bass has been very poor. D-1485 standards provide inadequate spring 



46 



outflow conditions for juvenile salmon; several years of data supporting this 
inadequacy have been collected since 1978. These are not yet standards for the 
protection of San Francisco Bay. These deficiencies will be addressed during 
upcoming hearings to be held by the State Water Resources Control Board. 

The Fish and Wildlife Service therefore recommends that for mitigation of the 
impacts of the COA: 

1. Multiple-level intakes to the outlet structures at Clair Engle and Shasta 
Lakes be provided to allow the best possible control of water tempera- 
ture for protection of downstream fisheries. 

2. Until multiple-level intakes to the outlet structures at Shasta and Clair 
Engle Lakes are in operation, storage be held at levels sufficient to 
assure that release water maintains the temperature in downstream 
reaches utilized by salmon for spawning and egg incubation at or below 
56 F. 

And in furtherance of the December 29, 1978 decision by the Secretary of the 
Interior to conserve fish and wildlife resources and specifically provide a 
guaranteed water supply to Central Valley national wildlife refuges, the Fish and 
Wildlife Service recommends:. 

3. Minimum flows from the Folsom Project to the lower American River 
be set at: 

a. No less than 1750 cubic feet per second from Nimbus Dam to the 
Howe Avenue Bridge from October 15 to December 31, for 
spawning salmon; 

b. No less than 1250 cubic feet per second from Nimbus Dam to the 
Howe Avenue Bridge from January 1 to March 31, for salmon 
incubation and rearing; 

c No less than 1250 cubic feet per second from Nimbus Dam to the 
mouth of the American River from April 1 to June 30, and such 
additional flow as may be required to prevent water temperature 
at the mouth of the American River from exceeding 65 F, for 
salmon rearing and out-migration; 

d. No less than 800 cubic feet per second from Nimbus Dam to the 
mouth of the American River from July 1 to March 31, for all 
fishery purposes. 

4. At least 60,000 acre-feet of water be reserved in Folsom Reservoir for 
release at the direction of the fishery resource agencies during the 
period October 15 to June 30 to facilitate upstream and downstream 
migration of salmon. 

5. The minimum flow from the Shasta/Trinity project to the Sacramento 
River be set at 6,000 cubic feet per second pending the results of a 2- 
year study currently being undertaken by the California Department of 
Fish and Game on the relationship of river flows to fish habitat in the 
river. 



47 



6. A firm annual supply of 211,000 acre-feet of Class 1 water be 
furnished, on a non-reimbursable basis, to Central Valley national 
wildlife refuges. 

7. A firm annual supply of 246,000 acre-feet of Class 1 water be 
furnished, on a non-reimbursable basis, to the Grasslands Resource 
Conservation District and Butte Sink Area to serve migratory bird 
needs. 

8. A firm annual supply of 78,000 acre-feet of Class 1 water be furnished, 
on a non-reimbursable basis, to the State of California's Los Banos, 
Mendota, and Gray Lodge Wildlife Management Areas. 

9. A firm supply of power be provided, on a non-reimbursable basis, to 
Central Valley national wildlife refuges, State waterfowl management 
areas, and to Coleman National Fish Hatchery. 

10. No further contracting of CVP firm supply for agricultural, municipal 
or industrial uses be undertaken until all fish and wildlife needs 
associated with the CVP have been identified, resolved, and solutions 
authorized. 

In a variety of ways and times the Service has previously informed the Bureau of 
Reclamation of the above needs and has requested that the CVP be reauthorized 
with fish and wildlife conservation as a co-equal purpose and the above basic and 
long-standing fish and wildlife needs for offsetting project impacts be provided. 
The Bureau has not supported these requests via the COA. The COA has been 
taken up by Congress without benefit of an accompanying Fish and Wildlife Coord- 
ination Act report Consequently, Congressional action taken to date does not 
include compensation for fish £ind wildlife impacts associated with implementation 
of the COA. 

As a result, this report is essentially an after-the-fact action. However, it is being 
submitted in comformance with our Coordination Act obligations and to again 
stress the need for our agencies to be in accord with the December 29, 1978 
Secretarial decision on operation of the CVP. Further, submission of this report 
affords yet another opportunity to resolve fish and wildlife resource needs before 
Congressional authorization of the COA. 

Please advise us of your proposed actions regarding our recommendations. 




lichard J. Myshak 



48 



UNITED STATES DEPARTMENT OF THE INTERIOR 

FISH AND WILDLIFE SERVICE 

Portland, Oregon 



A DETAILED ASSESSMENT 

OF THE 

CENTRAL VALLEY PROJECT/STATE WATER PROJECT 

COORDINATED OPERATION AGREEMENT 



(This detailed assessment plus the covering 

memorandum of November 26, 1985, constitutes 

the Coordination Act Report) 



49 



INTRODUCTION 

This is our detailed report of the effects on fish and wildlife resources of 
implementing the "Proposed Agreement between the United States of America and 
the Department of Water Resources of the State of California for Coordinated 
Operation of the Central Valley Project and the State Water Project." The 
proposed agreement, dated May 20, 1985, and commonly referred to as the 
Coordinated Operation Agreement, or COA, would make possible more efficient 
operation of the Federal Central Valley Project (CVP) and the State Water Project 
(SWP). Additionally, under terms of the COA the Bureau of Reclamation would be 
obligated to operate the CVP to meet the water quality standards for protection of 
the Sacramento-San Joaquin Delta set by the State Water Resources Control Board 
in Decision 1485. 

Considering the great importance of the resources that would be affected by the 
proposed action, this report is inappropriately brief because of the extremely short 
time allotted for its preparation. No time was available for studies or generation 
of project-specific data on our part. Existing data had to be used for our analyses. 
Geographic areas covered include the Sacramento-San Joaquin Delta, the entire 
Central Valley (including Federal and State water service areas), the San Francisco 
Bay system, and the Trinity River basin. Our analysis is based on information 
provided by the Bureau of Reclamation prior to June 1, 1985 — including the draft 
COA; operation studies at 1980 and 2020 levels of development under Tracy (in dry 
and critically dry years only) and D-1485 water quality standards; and the internad 
review draft Environmental Impact Statement/Environmental Impact Report on the 
COA, dated May 21, 1985. This analysis is valid only for the draft COA of May 20, 
1985. In the event that the draft COA is modified before it is submitted to the 
Congress for ratification, a revision of this report may be necessary. 

The COA establishes a formula for CVP-SWP sharing of exportable water from the 
Delta and for sharing of responsibility for supplying water to the Delta and the 
Sacramento basin. It also allows for improved estimates of project yield, and 
facilitates marketing of the available water resource. A consequence of imple- 
menting the COA would be that D-1485 standards would be met in aU years, unless 
the parties to the agreement should seek relaxation of the standards in critically 
dry years. The standards were relaxed during the 1977 drought. During that period 
water conditions were so critical that the only way the standards could have been 
continually met would have been to greatly reduce the delivery of water to the 
service area or to have drawn the reservoirs below their minimum power- 
generating pools. 

Our recommendations for the protection of fish and wildlife resources are based on 
the Fish and Wildlife Service's Mitigation Policy (Federal Register 46:15, January 
23, 1981) which provides internal guidance for establishing appropriate compen- 
sation for projects under our purview. Under the policy, resources are assigned to 
one of four categories to assure that our recommendations for compensation are 
consistent with the fish and wildlife values involved. The resource categories 
cover a range of habitat values from those considered to be unique and irreplace- 
able to those believed to be of relatively low value to fish and wildlife. The 
Mitigation Policy does not apply to threatened and endangered species. 



50 



The Mitigation goals for the four categories are; 

Resource Category 1 - No loss of existing habitat value 

Jlesource Category 2 - No net loss of in-kind habitat value 

Resource Category 3 - No net loss of habitat value while minimizing loss of 

in-kind habitat value 
Resource Category 4 - Minimize loss of habitat value. 

In accordance with the Mitigation Policy, the following category designations were 
made: 

Resource Resource Category 

Winter-run Chinook salmon 1 

Anadromous fish other than winter-run Chinook 2 

Migratory birds 2 

Non-migratory fish and wildlife (basinwide) 2 and 3 

Non-migratory wildlife on service area lands 2, 3 and 4 

Non-migratory fish in water distribution facilities 4 

Winter-run chinook salmon habitat has been identified as resource category 1 for 
all the possible reasons. Winter-run chinook salmon are unique to the mainstem 
Sacramento River; they are not found elsewhere in the nation. Their habitat 
appears irreplaceable. Sacramento River winter-run chinook salmon habitat is of 
high value unless degraded by adverse water temperatures. 

Other anadromous fish and migratory bird habitat has been identified as resource 
category 2. All anadromous fish habitat is scarce on a regional basis. The vast 
majority of stream miles of salmon and steelhead trout habitat has been severed by 
dams. The few remaining miles accessible to anadromous salmonids are often large 
rivers but they are not without problems. Salmon and steelhead populations are 
greatly diminished. Migratory bird habitat is also scarce, particularly for birds 
dependent on emergent wetlands and woody riparian vegetation. 

Habitat for resident fish and wildlife have been placed in resource categories 2, 3, 
or 4 depending on values, scarcity, replaceability, etc On the average it would be 
identified as resource category 3. 

In many cases resources assigned to different resource categories exist in the same 
space such as is the case with anadromous fish and non-migratory fish. Where that 
occurs, our recommendations for resource protection are dictated by the most 
valued resource. 

Analysis of the environmental impacts of the proposed action has, like the planning 
for the action itself, been a joint Federal-State endeavor. Input to the draft 
Environmental Impact Statement/Report, in large part the basis for this report, 
was performed jointly. The Department of Fish and Game did the impact analyses 
relating to the Bay and Delta fisheries, Suisun Marsh wildlife, and SWP service area 
fish and wildlife. The Fish and Wildlife Service was responsible for impact analyses 
relating to rivers inland of the Delta, reservoirs, CVP service areas, and 
endangered species. 



51 



The Fish and Wildlife Service concurs in the Bureau of Reclamation's biological 
assessment that the proposed action would not significantly affect any federally 
listed threatened or endangered species. 

DESCRIPTION OF THE PROPOSED ACTION 

The proposed action has been identified by the Bureau of Reclamation (BR) and the 
Department of Water Resources (DWR) as the signing and implementation of the 
Coordinated Operation Agreement. The COA consists of 22 articles and six 
exhibits: 

Article 1, Preamble 

Article 2, Explanatory Recitals 

Article 3, Definitions 

Article 4, Term of Agreement 

Article 5, Facilities 

Article 6, Coordination of Operations 

Article 7, Forecasting 

Article 8, Water Measurement Responsibilities 

Article 9, Reduction in United States and State Exports 

Article 10, Exchanges, Conveyances, and Purchases of Water Supply 

Article 11, Delta Standards 

Article 12, Monitoring 

Article 13, Records 

Article 14, Periodic Review 

Article 15, Relation to Agreement of May 16, 1960 

Article 16, New Facilities 

Article 17, Project Service Areas 

Article 18, Third Party Rights Unaffected 

Article 19, Effect of Waiver of Breach 

Article 20, Equal Employment Opportunities 

Article 21, Contingent Provisions 

Article 22, Officials not to Benefit 

Exhibit A Standards for the Sacramento-San Joaquin Delta 

Exhibit B-1 Central Valley Project and State Water Project Annual Supplies 

Exhibit B-2 Central Valley Project and State Water Project Full 

Development Annual Supplies 
Exhibit C Monitoring Locations 
Exhibit D Exchange Procedure to Provide D-1485 Condition 3 

Replacement Water (Article 10b of COA) 
Exhibit E Water Shortage and Apportionment 

Implementing the COA would accomplish the following: 

1. Commit both the CVP and SWP to meet D-1485 water quality and outflow 
standards for the Delta. 

2. Require quantification of annual water supplies of the CVP and SWP, 



52 



3. Establish new sharing formulas: 55 percent CVP, 45 percent SWP when 
adding to export or storage; and 75 percent CVP, 25 percent SWP during 
periods of storage withdrawaL 

4. Establish exchange arrangements under which the CVP and SWP convey 
water, and require negotiation between the two parties for conveyance and 
purchase of CVP water. 

The BR and DWR have identified the no-action alternative as not implementing the 
COA. A probable future in that case is that both projects would be operated per 
the draft COA, except that BR compliance with the State's Delta standards would 
not be assured in critically dry years. In such years, the BR might only meet the 
standards contained in contracts with the Delta-Mendota Canal users. Those water 
quality standards, known as the Tracy standards, are less stringent than the D-1485 
standards. The DWR would have three options in the event that the BR chose to 
meet only the Tracy standards in critically dry years. These would be to (1) meet 
Tracy standards (2) contribute the State's share toward meeting D-1485 standards, 
or (3) independently meet the entire D-1485 standards. Thus, there are actually 
three scenarios under the no-action alternative. Implementing the proposed action 
would reduce the potential annual firm yield of the CVP and SWP by about 130,000 
and 200,000 acre-feet, respectively, assuming that both the CVP and SWP under 
the no-action alternative were to meet only Tracy standards. If, however, DWR 
opted under the no-action alternative to meet the SWP's share of D-1485 standards, 
the SWP annual firm yield would decrease by only 143,000 acre-feet Since neither 
BR nor DWR has identified the most probable of the three no-action scenarios, we 
have assumed that the proposed action limits the potential annual firm yield for 
the CVP and SWP by 330,000 acre-feet. The COA identifies a CVP firm yield 
estimated at 8.2 million acre-feet under full development (2020 conditions). As 7.3 
million acre feet CVP firm yield are already under contract, this means that there 
would be an uncommitted firm supply of 900,000 acre-feet There are no operation 
studies that describe the impacts of managing interim and intermittent water, thus 
we cannot quantify the environmental impacts of those operational actions. (Our 
interpretation of interim water is that it is "firmly developed" but is either not 
committed in long-term contracts, or, if committed, is not being used to the full 
contract allowance. Intermittent water is understood to be water that is not sold 
under long-term contracts because it is unavailable in dry years.) 

In the absence of D-1485, the BR's target standards for the Delta would likely be 
something less than the State standards (at a minimum the Tracy standards). 
Under that assumption, the effect of CVP operation on CVP-con trolled reservoirs 
and river reaches would be quite different than under current operation wherein 
the BR endeavors to meet D-1485 standards whenever possible. In our opinion, the 
difference could be expressed in terms of yield of interim and intermittent water, 
a display of which is not provided by the operation studies. The no-action 
alternative that the BR and DWR have identified, however, is that the CVP would 
be operated to meet D-1485 standards in all but critically dry years. Since the 
proposed action would require the BR to meet D-1485 standards in all years, not 
just extremely dry years, it is our view that the no-action operation studies used 
for analysis are inappropriate. 

The CVP and SWP are operated on a basis of supply and demand for agricultural, 
municipcd, and industrial uses, taking into account flood control, navigation, power 



53 



generation, fish and wildlife, and recreation. Risk involved in assessing what the 
water supply is, or will be, is an unavoidable element in decision-making on water 
flow management. Because of the many competing needs there are not always 
firm gmdelines for day-to-day management of water projects; thus, operation 
studies cannot address the impacts of short-term operation decisions. When supply 
exceeds demand there is opportunity to operate flexibly. Such was the case in 1978 
when D-1485 was adopted and the Secretary of the Interior determined that the 
CVP could be operated, for the interim at least, to meet those standards in all but 
the driest years. Such decisions have an impact In the case of D-1485 the impacts 
were beneficicd (as intended) in the Delta, but unintentionally adverse in certain 
river reaches. The adverse impacts to rivers occur in all years, although they are 
most pronounced during and immediately following critically dry years. Impacts 
occur on a daily basis even in years of above-normal water availability. Mean 
monthly operation studies do not account for these occurrences, however. Fish 
population levels for an extended period could be determined by only a few hours of 
low flow. For example, a 12-hour flow of 500 cfs during a month having an average 
flow of 10,000 cfs could effectively limit population levels to that which can be 
supported by a flow of 500 cfs. 

A major purpose of the proposed action is to afford environmental protection to 
the Sacramento-San Joaquin Delta, specifically through maintenance of water 
quality and outflow standards that protect fish and wildlife resources. The 
protection provided for Delta resources would be an improvement over that which 
existed before the administrative action taken by the Secretary of the Interior in 
1978, and that which would exist in the future without the proposed action, but 
would not allow for fish and wildlife levels that might have persisted in the absence 
of the CVP and SWP. 

A 1978 written decision of the Secretary of the Interior intended not only to enter 
into a COA, but also to have legislation enacted that would amend the Central 
Valley Project authorization to: (1) clearly provide as a project purpose the 
conservation and development of fish and wildlife resources, with associated costs 
of new (post 1978) water supplies for fish and wildlife designated as non- 
reimbursable, and (2) assure a guaranteed water supply to Central Valley national 
wildlife refuges. Those objectives are not provided for under the proposed action. 

The only alternatives reported on herein are the proposed action and no action 
alternatives. Two other alternatives ("modified agreement" and "no coordination") 
are not addressed in this report because they have not been sufficiently defined by 
the BR and DWR. 

THE AFFECTED ENVIRONMENTS 

Fish and wildlife habitats that would be affected by the proposed action occur in 
(1) the Sacramento-San Joaquin Delta — its waterways, agricultural lands, and 
Suisun Marsh, (2) the Central Valley — especially CVP/SWP-con trolled rivers and 
reservoirs, and CVP/SWP water service areas, (3) the San Francisco Bay system 
upstream to the western boundary of the Delta, and (4) the Trinity River basin — 
principally Clair Engle and Lewiston Lakes and reaches of the Trinity River. 



54 



The entire Sacramento-San Joaquin Delta would be affected by the proposed 
action. The State Water Resources Control Board's Decision 1485, which in large 
part instigated the need for the proposed action, was intended to provide greater 
protection for agricultural, municipal and industrial water supplies, and for fish and 
wildlife resources in the Delta. The Delta is a 700,000-acre expanse encompassing 
about 510,000 acres of farmland on 60 major islands. Since much of the farmland 
is below mean sea level (as much as 20 feet below), 1,100 miles of levees are 
needed to protect the islands from the 700 miles of tidal Delta waterways. 
Production of grain, hay, and pasture account for much of the agricultural use. 

California's Central Valley measures roughly 40 miles in width and 450 miles in 
length and is comprised of the Sacramento VaDey in the north and San Joaquin 
Valley in the south. Agricultural development has been largely responsible for the 
loss of about 95 percent of the valley's original 4 million acres of marshlands. 
Woody riparian habitat has fared even less well, having been reduced to only 2 
percent of the historical acreage. Other natural habitats in the Central Valley are 
also scarce. CVP agricultural service areas total about three million acres. SWP 
agricultural service areas are less extensive but include lands outside the Central 
Valley. 

CVP/SWP-controlled reservoirs and rivers are shown in Figure 1. AU or portions of 
the three largest rivers in the Sacramento Valley (the Sacramento, Feather and 
American) have had their flow and temperature regimes significantly affected by 
either the CVP or the SWP. 

The San Francisco Bay system would be affected by the proposed action from the 
mouth of the Bay at the Golden Gate to the western edge of the Delta. This area 
encompasses about 270,000 acres of open bay and about 85,000 acres of 
surrounding tidal marsh and mudflat. Depending on freshwater runoff conditions, 
the estuary can vary in salinity from nearly marine to almost fresh conditions. 

In the Trinity basin Clair Engle and Lewiston Lakes and the Trinity River would be 
affected. Since the Trinity River is tributary to the Klamath River, the proposed 
action could conceivably impact the Klamath system; however, the impacts would 
likely be negligible. 



03 






wMsnrTowH HZ 



SAOiAldEHTO RIYE/f 




gure 1: MAJOR FEATURES 
OF THE SWP AND CVP 



CONTRA QSTA CAMAL 

JOUTX 8iT AoueoucT 

&M LUIS «fSl 



DELTA- MCNOOTi CANAL 



fOLSOU LAKt 

MfV tffi0/ir£3 «ri 
N. 

^ SAN JCAQWn'^IVER 

\«MAOC!<A CANAL \^ 
SAN LJIS CAN^L 

r*. '' 

I -^lAMT-KE'^N CANAL 

S 

CAL.sCSSIi 40UE2UCT 



-'*— W/Llf^TV cjirr ' 



\ 



\ 



LEGEND 

5TATC UTCT WOJKT 
CtNTHAL '.ALLiY s^jECT 
JOINT USE fAClLlTlEi 




\ 



I 

J 

( 
\ 



RESOURCES WITHOUT THE PROPOSED ACTION 
Delta ' 

Fishery resources using the 700 miles of Delta waterways include both anadromous 
and resident fishes. The most important of the anadromous fishes are Chinook 
salmon, striped bass, American shad, and white sturgeon. Fish habitat and 
populations are much reduced from pre-CVP/SWP levels. 

Chinook salmon pass through the Delta on their way to spawning sites in the rivers 
and stream of the Central Valley. Upstream migrants now number only about 
250,000 annually on the average, varying widely from year to year. Most ascend 
the Sacramento River system. The Delta is believed to play a significant role in 
the rearing of juvenile Chinook salmon in some years, and in all years the Delta 
environment has much to do with the overall survival of downstream migrant 
salmon and the upstream migration of adult salmon. Water quality, food 
availability, channel velocities, circulation patterns, water diversions, and 
predation all interact to affect fish survival. 

Adult striped bass, once numbering about three million in the early 1960's, have 
declined to less than one million. The striped bass fishery is a complex estuarine- 
based resource, the management of which requires an understanding of their water 
quality and quantity needs, transport mechanisms, food base, and other factors. In 
recent years the correlation between a computed index (based on measurable 
environmental variables) of young-of-the-year striped bass and observed levels has 
been poor, with the observed levels (i.e., net samples) being much lower than com- 
puted levels. On 1985 the actual index was 6.3. Environmental variables indicated 
it should have been about 30. Previous ranges were from 10 (1977) to 120 (1965 and 
1967). The understanding of this problem is poor. 

From 1.5 to 2.5 million adult American shad migrate through the Delta enroute to 
freshwater spawning sites, primarily in the Sacramento River system. The Delta is 
an important rearing area for juvenile shad. 

The 1979 population estimate of legal-sized white sturgeon was 75,000 fish. Adult 
sturgeon pass through the Delta on their spawning runs and the Delta is also an 
important rearing area for juveniles. 

Resident fish species, particularly the white catfish, are numerous and important 
to the sport fishery. 

Wildlife species in the Delta are associated with both farmlands and waterways. 
Migratory birds that winter in the Delta, often feeding on agricultural lands, 
constitute the most important use of this area by wildlife. Suisun Marsh, i. 55,000- 
acre wetland complex in the western Delta, is an especially important waterfowl 
area. 



57 



Central Valley 

There is some quantitative information on fish resources of CVP- and SWP-con- 
troUed rivers and reservoirs, but comparable information on wildlife is lacking. 
There are no reliable quantitative descriptions of fish and wildlife resources of the 
CVP and SWP water service areas (i.e., where water is consumed). Qualitative 
information, such as what types of fish and wildlife comprise various terrestrial 
and aquatic communities m the service areas, does exist, however. 

Two major Central Valley rivers, the Sacramento and American, that are 
controlled by the CVP support important fish resources; Chinook salmon, steelhead 
trout, American shad, and striped bass. Salmon in particular could decline 
substantially in the next 40 years under the no-action alternative as use of 
developed water supplies reaches the ultimate-use level. Current planning 
activities and hoped for improvements, however, should bring about a restoration 
of salmon habitat and populations, particularly in the Sacramento River between 
Keswick and Red Bluff Dams. There are no estimates of what those future levels 
of salmon are expected to be but hopefully they will be more than doubled in the 
Sacramento River. Corrections ultimately anticipated include improvement of 
salmon passage at Red Bluff Diversion Dam, a reduction in pollution emanating 
from the Spring Creek drainage, improved production of salmon and steelhead trout 
at Coleman Hatchery and Tehama Colusa Fish Facility, temperature control for 
releases at Shasta Dam, etc. An important aspect of the Sacramento River is that 
is supports four races of chinook salmon (fall, late-fall, winter and spring). Present 
spawning escapements average about 127,000 and 47,500 fish for the Sacramento 
and American Rivers, respectively. 

The main SWP-con trolled river is the Feather. Salmon spawning escapement 
averages about 50,000 fish annually. We have no data to indicate whether or not 
resource levels would change during the period of analysis for the no action 
alternative. Because the SWP is short of developed water supply, we suspect that 
existing water use from the Feather will change little under ultimate conditions, 
unlike CVP-controlled rivers. 

In addition to sfidmon, portions of these major rivers support steelhead trout, 
striped bass, American shad, sturgeon, lamprey, trout emd other fishes. Most of 
these resources are highly valued. These other species are not dealt with in detail 
in this report because impacts of the proposed action are likely very small to 
negligible and the biological information and operation studies available with which 
to analyze the impacts are inadequate. 

The fish resources of CVP- and SWP-con trolled Central Valley reservoirs that 
would be affected by the proposed action, prim«u*ily in Shasta, Folsom, and Oroville 
Lakes, are resident warm- and cold-water fishes. Collectively, these three reser- 
voirs total about 53,500 surface acres and support significant angler use. 

Other reservoirs that could possibly be affected by the proposed action are San 
Luis, Natoma, Thermalito, Keswick, and Whiskeytown. All but San Luis are re- 
regiilating facilities for major storage reservoirs. Because of the low potential for 
impacts we have not discussed the resources of these waters. 

Wildlife associated with rivers, reservoirs and water service areas include 
mammals, reptiles, amphibians, and both resident and migratory birds. 



58 



San Francisco Bay System 

The estuarine and marine fish and wildlife resources that use the Bay complex 
could change significantly by 2020 under the no-action alternative. Further 
depletion of Delta outflow/Bay inflow on the order of a few million acre-feet is 
possible. Compared with a current Bay inflow averaging about 15 million acre-feet 
per year, and a pre-water development average of over 30 million acre-feet, this 
would be a significant change. The effects of reduced fresh water inflow are being 
studied but results are several years away. The effect of reduced outflow to San 
Francisco Bay causes significant physical and biological changes; the ecological 
significance is not completely defined, however. A good reference on this is 
Technical Report No. 7 of the Four-Agency Ecological Study Program in the Bay- 
Delta Estuary, Herrgesell et al., 1983, titled "Effects of Fresh Water Outflow on 
San Francisco Bay Biological Resources". Present guidelines for freshwater inflow 
call for surges in Delta outflow of at least 10,000 cfs within a 5 to 10-day period on 
an average of four times per year, and at least once yearly during dry years (Water 
Quality Control Plan, Sacramento-San Joaquin Delta and Suisun Marsh, August 
1978, State Water Resources Control Board). 

Trinity River Basin 

Clair Engle and Lewiston Lakes, and 40 miles of Trinity River from Lewiston 
downstream to the North Fork Trinity confluence, are the waters of the basin that 
would be affected by the proposed action. Neither wildlife nor lake fisheries would 
be significantly affected, so only the fish resources of the Trinity River are 
addressed herein. Under the no-action future, we would expect sutstantial 
increases in the anadromous fishery. The goal of the recently funded, $57-million 
Trinity River Basin Fish and Wildlife Management Program is restoration of the 
basin's natural resources, especially salmon. Restoration could bring about a 
several-fold increase in the existing level of about 10,000 salmon spawners. 

RESOURCES WITH THE PROPOSED ACTION 

Delta 

An analysis of impacts of the proposed action on Delta fish and wildlife resources 
was provided by the California Department of Fish and Game. Quantification of 
impacts in terms of fish numbers or fish habitat alteration was not provided, but 
impacts were described in terms of "better" or "worse". Fish resources considered 
were striped bass, salmon, and resident fishes. Analysis of wildlife resources 
focused on Suisun Marsh as that is where the most measurable effects would occur. 

With respect to striped bass, the proposed action would: 

1. Keep salinity in the lower San Joaquin River within the range preferred 
for spawning in critically dry periods. 

2. Keep the estuarine entrapment zone in Suisun Bay, thereby providing for 
greater food supply, and 

3. Keep reverse flows in the lower San Joaquin River at at>out 800 cfs in 
critically dry years, rather than at 2100 cfs. 



10 39 



With respect to salmon, the proposed action would: 

Keep flow reversals in the lower San Joaquin River to a minimum, thereby 
promoting positive migration of juvenile Chinook. 

In general, critical-year operation of the CVP and SWP would be beneficial to 
Delta migratory fishes and harmless to resident fishes. 

Impacts on Delta wildlife would be negligible with the proposed action except in 
Suisun Marsh where, given the existing water control facilities in the marsh, the 
production of alkali bulrush seeds (a major food item of waterfowl) would be about 
20 percent higher in critically dry years. 

Central Valley 

The proposed action would have a net adverse effect on fish and wildlife resources 
in the CVP/SWP service areas if it results in the contracting of more firm water. 
The Fish and Wildlife Service is of the opinion that the contracting of firm water 
to already-developed agricultural lands is adverse to fish and wildlife because in 
many cases it allows the freeing up of groundwater that is used to convert 
undeveloped or partially developed lands to a more intensive agricultural use and 
eventually the owners of those lands seek and obtain a firm surface supply. 
Impacts could vary widely for individual contracts and would be the subject of 
separate analyses and environmental documentation. 

Implementation of the proposed action would affect certain reservoirs, rivers, and 
floodplain lands in the Sacramento, Feather and American drainages, but for all 
practical purposes, reservoir fishery and terrestrial wildlife habitats are not 
expected to be significantly affected. The adverse impacts on river fisheries can 
be assessed and are, in fact, the most significant attributable to the proposed 
action. Water temperatures and flow rates in rivers immediately below CVP-and 
SWP-controlled reservoirs are the principal environmental factors that would be 
changed. River temperatures would change because of: (1) different patterns in 
reservoir storage and therefore release elevation relative to lake surface, and (2) 
different river flows and therefore differences in the water's time of travel. 
Relative to the no-action alternative, the proposed action would cause small but at 
times highly significant changes in the temperature of water released from the 
major storage reservoirs. Changes in water temperatures due to altered storage 
levels could be considerably more significant than changes in river flows. Impacts 
were assessed from analysis of monthly reservoir and river operation studies emd 
water temperature studies beised thereon. Operation studies were provided by the 
BR and DWR; BR alone supplied the water temperature studies. 

Severe adverse impacts to the Sacramento River would occur during critically dry 
periods, and the periods immediately following when Lake Shasta would be 
refilling. The proposed action would cause slightly increased spring flows, 
decreased winter flows, and lower lake levels overall The impact of the flow 
changes on fish has not been quantified because there has not been a study of the 
relationship of flow to fish habitat in the Sacramento River. Thus, judging the 
adverse effect of flow changes alone on fish habitat and fish populations must 
remain speculative. 



60 U 



Implementation of the proposed action would increase the temperature of water 
released from Keswick Dam (the re-regulating reservoir for the Shasta-Trinity 
operation) during the months of May through November. During these times water 
temperatures are presently often marginal to unsuitable for salmon. In a 1933-type 
year, i.e., a "worst case" critically dry year, the proposed action would cause a rise 
of up to 1^ at the 1980 level of development and up to 4 F at the 2020 level of 
development The 2020 level projections reflect absolute temperatures of 59, 62, 
82, and 59°F for the months of July through October; much too warm for salmon 
spawning and egg incubation. An analysis performed by the BR and presented in 
the September 18, 1985 DEIS/EIR is based on a mathematical model incorporating 
hydrological parameters and biological parameters (provided by the Fish and 
Wildlife Service) and expresses losses with the proposed action as a percentage that 
would occur in a 1933-type water year. The Fish and Wildlife Service has further 
used this data to estimate that adult spawning escapement would be reduced by 
3,500 and 7,600 salmon, respectively, at 1980 and 2020 levels of development 
Important to note is that 1,400 and 5,000 of the fish lost (1980 and 2020 conditions, 
respectively) would be winter-run Chinook salmon, a race designated as Resource 
Category 1 for which the mitigation goal is no loss of existing habitat value. For 
the last 3 years the spawning escapement of winter-run chinook salmon has 
averaged only 2,000 fish. Loss of salmon in other types of water year has not been 
estimated. An annualized figure for the loss of salmon due to the proposed action 
cannot be determined. 

Impacts of the proposed action on Feather River fishery resources would be minor. 
Selective level intakes to the outlet at Oroville Lake reach deep into the pool and 
can provide water of suitable temperature under all, or nearly all, reservoir storage 
conditions. Changes in flow to the Feather River would be small and the impact on 
salmon habitat could perhaps be slightly beneficiaL 

Impacts of the proposed action on the American River fishery would be significant 
The action would cause Folsom Lake levels, on the average, to be 3 to 25 feet 
lower in 16 out of every 600 months. This would occur at times when water 
temperatures are critically important to salmon. Although the intake to the outlet 
at Folsom Lake has multiple-level selectivity, water of suitable temperature 
cannot always be reached. The impact of unsuitable temperature in a 1933-type 
water year could equate to a loss of several thousand adult salmon. The impact on 
salmon of flow-rate changes would be negligible. 

San Francisco Bay System 

The proposed action would lessen peak Delta outflow/Bay inflow during winter in 
critically dry years and the year or years immediately following critically dry 
years. This would have an adverse impact on Bay fishes and, to a lesser extent, 
Bay wildlife. Average Delta outflow/Bay inflow would be slightly higher during 
summer and fall in critically dry years with the proposed action and therefore 
slightly beneficial to the Bay. The net effect of the proposed action would be 
adverse. The Bay complex is a system that best functions ecologically under 
naturally varying hydrologic conditions. High flows to the Bay flush pollutants, 
beneficially alter salinity, transport larval fish and shellfish to more desirable 
areas for growth, etc. 



« 



Trinity River Basin 

Releases to the Trinity River from Lewiston Reservoir are presenUy near fuUy 
controUed. The proposed action and the no-action alternative thus do not differ in 
river flows. Because of exports from the Trinity River basin to the Sacramento 
basin, however, storage levels in Clair Engle and Lewiston Reservoirs differ 
between the two alternatives, causing differences in the temperature of the 
release water to the Trinity River. Temperature increases under the worst case 
condition (Le., 1933) would be 1, 3, and 4^, respectively, for the months of 
August, October, and November at the 1980 level of development, reflecting 
absolute water temperatures of 62 and 61 F during October and November; much 
too high for survival of salmon at spawning. At the 2020 level of development, the 
proposed action would cause an increase of 1 F during the month of October under 
the worst case condition, reflecting an absolute water temperature of 49°F — not a 
problem for salmon. Temperatures in other months would not be affected by the 
proposed action. Temperature increases in the fall at the range of 57 F and at>ove 
are especially harmful to spawning salmon. In the months of October and 
November of the worst case condition, at the 1980 level of development, the 
impacts would be such that a major fraction of the upper river salmon spawn would 
be lost. Also, operation of Trinity River hatchery would be impaired. The number 
of adult equivalents lost could be on the order of several thousands of fish, 
depending on the level of restoration that will have taken place because of the 
Trinity River Basin Fish and Wildlife Management Program. Wildlife resources of 
Clair Engle and Lewiston Reservoirs, and wildlife resources associated with the 
Trinity River, would not be significantly affected. 

DISCUSSION 

The decision of the Secretary of the Interior in 1978 relative to the Delta Water 
Quality Control Plan and the COA was that, among other thing, the Secretary 
would propose legislation to Congress that would: 

1. Authorize the CVP to meet State standards. 

2. Authorize the relocation of the Contra Costa Canal intake 

3. Amend the CVP authorization to clearly provide that: 

a. conservation and development of fish and wildlife resources, and 
maintenance of the quality and quantity of all waters affected by the 
project , including the estuary, are authorized purposes of the CVP, with 
the objective of maintaining fish and wildlife at recent historical (1922- 
1967) levels, and 

b. equal consideration be given to fish and wildlife in the development and 
allocation of any new water supplies, and that all costs for such water 
be non-reimbursable. 

4. Authorize provision of a guaranteed water supply to Central Valley national 
wildlife refuges. 

5. Authorize the implementation of a Coordinated Operation Agreement 
between the Burean of Reclamation and the California Department of Water 
Resources for operation of the Central Valley Project and State Water 
ProjecL 



62 13 



The Secretary further directed no additional commitment for sale of CVP water 
until the issue of instream flow needs in the areas of origin has been resolved and 
until the water needs of Central Valley national wildlife refuges have been met 

The Secretary's 1978 decision set forth a comprehensive solution to many of the 
problems and issues that have surrounded both the Central Valley Project and the 
State Water Project. To date, however, none of the points addressed in that 
decision have been pursued to any extent by the BR except the Coordinated 
Operation Agreement. The present proposal to seek authorization for 
implementing the COA does not address those other issues. Moreover, if the COA 
is implemented alone, it may preclude satisfactory resolution of several of those 
issues. Of greatest concern to the Service are the matter of instream flow needs 
(quality and quantity) of all waters affected by the CVP, and the issue of water for 
refuges. We feel very strongly that the comprehensive approach provides the only 
equitable means for achieving solution to those issues. Conversely, we feel that 
any further commitment of CVP water in the absence of a comprehensive solution 
is counterproductive. 

Based on our analysis of the available fish and wildlife information and the Bureau 
of Reclamation's description of the proposed action, implementation of the COA 
would impact fish and wildlife resources in five ways. 

1. Beneficially impact striped bass and salmon habitat in the Sacramento-San 
Joaquin Delta . This would come about through a more favorable salinity 
level for striped bass spawning in the lower San Joaquin River; maintenance 
of the location of the nutrient entrapment zone in Suisun Bay; and, to the 
benefit of both striped bass and salmon, reduced magnitude of flow reversal 
in the lower San Joaquin River. The degree of beneficial impact has not been 
quantified. In the last seven years actual numbers of young-of-the-year 
striped bass have been significantly lower than the levels predicated by river 
flows and diversion rates — about 1/3 to 1/2 of the predicted levels. The fact 
that striped bass numbers have declined in the last seven years even though 
D-1485 standards have been in effect and met cautions us that the beneficial 
effect of D-1485 standards may not accomplish what they were intended to. 

2. Beneficially impact waterfowl habitat in Suisun Marsh . A benefit would be 
realized in critically dry years with the proposed action due to the 
availability of better quality water for distribution to the marsh. The seed 
production of waterfowl food plants would thus be 20 percent higher in 
critically dry years than would be the case under the no-action alternative. 

3. Potentially Adversely impact fish and wildlife habitat in Federal and State 
water service areas . The impact of the proposed action would be adverse if 
it made additional project water available for irrigation. Both the amount 
and quality of habitat suitable for fish and wildlife would diminish as more 
land is put to agricultural use and as that land already farmed is used more 
intensively. 



4. 



Potentially Adversely impact fish and wildlife habitat in San Francisco Bay . 
The overall reduction of flow into San Francisco Bay made possible with the 
proposed action would, in the opimion of the Fish and Wildlife Service, be 
detrimental to fish and wildlife resources. The adverse impact could be 



14 63 



64 



avoided by aUowing sufficient Delta outflow to maintain Bay hydrodynamics 
and water quality. Some of the compensatory measures identified for salmon 
would benefit the Bay. For example, operating for higher storage levels so 
that water releases would be of more suitable temperature would reduce 
winter storage capabilities, and that would mean more releases for the 
purpose of flood control and hence more uncontrolled outflow to the Bay. 
The COA does not preclude uncommitted yield from being used for San 
Francisco Bay fish and wildlife, but the highly improbable that it would ever 
occur. 

5. Adversely impact salmon habitat in the Sacramento, American and Trinity 
Rivers . Multiple-level intakes to the outlets at Shasta and Clair Eagle Lakes 
are needed for temperature control with the existing project operation, and 
the need would be even greater with the proposed action. Given existing 
outlet facilities, the only way to avoid the adverse river water temperatures 
attributable to the proposed action would be to manage reservoir storage 
levels so that water of suitable temperatures could be released In the event 
of a series of dry water years, however, that measure might not be possible. 
For the Sacramento River, the impact of the proposed action could extirpate 
the winter-run race of salmon and further decimate the spring and fall runs. 

The flows that would be provided to the Sacramento and American Rivers at full 
development under both the no-action and proposed action alternatives would be 
inadequate for salmon and other anadromous fishes. This is because the minimum 
flows agreed to at the time the Shasta project was constructed in the 1940's and 
the Foisom project in the 1950's do not provide reasonable instream habitat and do 
not always allow the necessary water temperatures be maintained throughout the 
important reaches. Minimum sillowable flows in the Sacramento River below 
Keswick Reservoir range from 2,300 to 3,900 cfs under normal conditions, and 
during critically dry years, 2,000 to 2,800 cfs. Given the present agreement for the 
American River, the minimum flow could become, as the operation studies reflect, 
250 cfs (increased to 500 cfs during the salmon spawning season). Whereas the 
minimum flows are now a rare occurrence they will be commonplace at the 2020 
level of development when full use of storage is made. The proposed action would 
increase the frequency at which inadequate flows occur. The minimum flows 
adopted years ago could thus soon become the maximum flows for much of the 
year. 

The adopted minimum flows are not capable of maintaining salmon and other 
anadromous fishes of the Sacramento and American River at even present levels. 
Until a fishery flow needs study for the Sacramento River is completed the Fish 
and Wildlife Service believes that an interim minimum flow from Keswick 
Reservoir to the Sacramento River of 6,000 cfs is needed. A much needed study is 
underway that will make flow needs a fact, not an opinion. For the American 
River, the FWS has completed a flow needs analysis as part of the BR's Auburn- 
Folsom South/Lower American River Alternatives Study (Flow Needs of Chinook 
Salmin in the Lower American River, Fish and Wildlife Service, May 1985). The 
analysis shows that the lowest flows in the American should be 1,750 cfs during the 
fall spawning period; 1,250 during the spring rearing and outmigration period (plus 
additional flow as necessary to keep river temperature suitably low); not less than 
800 cfs from July 1 through March 31; and a 60,000 acre-foot block of water 
additional to be released on an as-needed basis for upstream and downstream 
migration of salmon in the American River. 



15 



In addition to the vulnerable winter-run salmon in the Sacramento River, the 
salmon and steelhead trout of the Trinity River require special attention in light of 
the recently initiated Trinity River Basin Fish and Wildlife Management Program, 
and especially in view of the Trinity River Division's authorizing statute. That 
authorization (Trinity River Act, P.L. 84-386) provides that, not withstanding the 
.purposes of the project, the Secretary is "...authorized and directed to adopt 
appropriate measures to insure the preservation and propagation of fish and 
wildlife, including, but not limited to, the maintenance of the flows of the Trinity 
River...". This essentially requires the Department to operate the Trinity River 
Division so that no net adverse effect to Trinity River fish and wildlife occurs. 

Consonant with the Secretary of the Interior's 1978 decision and rationale relative 
to maintaining fish and wildlife resources at recent historical levels is the need to 
provide a gucu'anteed water supply for Central Valley national wildlife refuges. 
These refuges, administered by the Fish and Wildlife Service, have a firm water 
supply of only about 22,000 acre-feet, most of which must be pumped from 
groundwater at considerable cost. The annual need is 211,000 acre-feet. When 
CVP interim and intermittent water is no longer available these refuges will have 
to rely totally on their our firm supply unless firm CVP water is provided. Today, 
only 4 percent of the Central Valley's historical 4,000,000 acres of wetlands 
remain. The need for a firm water supply for Central Valley national wildlife 
refuges is great; the intent of the Secretary in 1978 was to guarantee that supply. 
The COA might preclude, or at least make more difficult, committing CVP supply 
for this purpose since it requires the BR to negotiate the sale of CVP water to the 
California Department of Water Resources (Article 10). The Federal refuges alone 
cannot provide habitat sufficient to maintain wintering migratory waterfowl and 
waterbirds of the Pacific Flyway;all Federal, State, and private wetland habitats 
are needed for this purpose. The Central Valley provides 60 percent of the Pacific 
Flyway's waterfowl wintering habitat. Waterfowl are an international resource 
protected by Migratory Bird Treaties, one in 1916 with Great Britain (for Canada) 
and another in 1918 with Mexico. 

Management of the State-administered areas, like the federally administered 
areas, is constrained by inadequate supplies of water. For that reason, this report 
include a recommendation that CVP water be furnished to meet the needs of the 
State's Los Banos, Mendota, and Gray Lodge Wildlife Management Areas. In recent 
years, privately owned wetlands in the Grasslands and Butte Sink areas of the 
Central Valley have been placed in the Service's Easement Acquisition Program. 
Management of these historically important waterfowl habitats is also constrained 
by a deficient water supply. The water requirements for all Federal-and State- 
administered areas, including non-easement areas within the Grasslands Resource 
Conservation District and the Butte Sink Area, are presented in Table 1. At this 
time, the BR should commit firm siirface supplies to meet the full need of these 
Federal and State wildlife areas. 



16 

65 



Table 1. 
ANNUAL CLASS 1 WATER REQUIREMENTS 

for 
FEDERAL, PRIVATE AND STATE MANAGEMENT AREAS 

in the 
CENTRAL VALLEY 

AREA REQUIREMENT (A.F.) 



FEDERAL 






Sacramento NWR 




50,000 


Delevan NWR 




30,000 


Colusa NWR 




25,000 


Sutter NWR 




30,000 


San Luis NWR 




19,000 


Merced NWR 




16,000 


Kesterson NWR 




10,000 


Kern NWR 




25,000 


Pixley NWR 




6,000 




SUB TOTAL 


211,000 


PRIVATE 






Grassland Resource Conservation District 


195,000 


Butte Sink Area* 




51,000 




SUB TOTAL 


246,000 


STATE 






Los Banos WMA 




25,000 


Mendota WMA 




19,000 


Gray Lodge WMA 




34.000 




SUB TOTAL 


78,000 



GRAND TOTAL 535,000 

* - As defined by the Fish and Wildlife Service in their Butte Sink Ascertainment 
Report 

Operation of the national wildlife refuges and fish hatcheries in the Central Valley 
is energy-intensive. In a hot, dry year as many as 10 million kilowatt-hours of 
electricity are required to operate the water chilling, heating, and treatment 
systems at Coleman National Fish Hatchery and the water requirements of the 
national wildlife refuges in the Central Valley. Escalating electrical energy costs 
are limiting the operation of these systems to less than the optimal leveL 

Examples of the urgent need for project power are as follows. The Coleman 
National Fish Hatchery was authorized as a part of the CVP as partial mitigation 
for the loss of natural spawning grounds caused by the construction of Shasta and 
Keswick Dams. However, unlike other project facilities, the Coleman hatchery has 
yet to be provided project power. Although the hatchery has a small allocation of 
preference power for the period 1982 to 1994, the allocation is insufficient for the 
operation of the chillers which are used to cool water for holding adult winter 
Chinook until they are ready to spawn. Under terms of a 1955 Memorandum of 
Agreement, BR transferred $48,000 to the FWS for construction of wells to provide 

66 

17 



groundwater for wetland maintenance at Merced National Wildlife Refuge. 
However, the escalating cost of commercial electricity to operate the pumps has 
resulted in a situation where the optimal wetland acreage at Merced can no longer 
t>e maintained. 

The provision of project power to the fish and wildlife facilities in the Central 
Valley would help compensate for the loss of natural spawning grounds, stabilize 
the decreasing wetland acreage, provide crop damage relief, and help meet treaty 
commitments to manage and preserve migratory waterfowL The amount of energy 
required would range from only 0.03 percent to 0.1 percent of the annual CVP 
generation. 

We believe that our assessment of the impacts of the proposed action on fish and 
wildlife resources is conservative for the following reasons. 

1. Numerous assumptions are implicit in the impact analysis as well as in the 
studies of hydrology and river water temperature . The proposed action will 
mean, among other things, a decision that the CVP will be operated to meet 
D-1485 standards in all years, including critically dry years. Yet, the only 
operation studies available to us are based on the assumption that the no- 
action alternative would mean meeting D-1485 standards in all but critically 
dry years. Our analysis, therefore, only quantifies the impact of meeting D- 
1485 standards in critically dry years. In the absence of a no-action 
alternative that involves meeting some other standard in all years, 
presumably Tracy standards, we could not perform the analysis we believe to 
be correct. 



2. Monthly hydrology and water temperature operation studies were utilized to 
assess impacts on fish and wildlife . Fishery resources are often limited by 
extreme conditions that occur on a daily or instantaneous basis —instan- 
taneous flow or temperature conditions can be quite different from avereige 
monthly conditions. Average monthly water temperature and instantaneous 
water temperature can vary by 10 F or moreL Certain life stages of salmon 
have a low or "normal" mortality rate at 56 F but suffer total mortality at 
62°F. In some years marginal and limiting temperatures occur in the 
Sacramento, Trinity and American Rivers under existing conditions — the 
proposed action would worsen the mortality rate. 

3. Time was insufficient for collection of all information needed. The 
relationship of flow and temperature to Sacramento River salmon habitat! 
and the relationship of Delta outflow to San Francisco Bay fish and wildiTe 
habitat, are obvious examples . Although Federal action on the COA has been 
anticipated since 1978, agreement on a final draft was not reached until May 
1985. There has been neither time nor funding to do an instream flow and 
water temperature needs study of the Sacramento River. While studies on 
the outflow needs of San Francisco Bay have been underway for several 
years, the results will not be available for some time. 

4. Long term and cumulative effects of the proposed action could not be 
addressed, only short-term and direct effects . Data were sufficient to 
address only the worst-case condition as would occur in 1933. For rivers, 



18 



67 



operation studies showed only 3 out of 83 years as having significant water 
temperature increases because of the proposed action. Chinook salmon have 
a life cycle such that they return as adults to freshwater at 2, 3, 4, or more 
years of age. If the freshwater phase of the salmon's life cycle could not be 
completed for 1 or 2 years, it would take many years for the affected 
population to rebuild. Such was the case with winter-run chinook salmon 
affected by the adverse water temperatures caused by the 1976 -77 drought. 
Population levels are still greatly depressed. If a population cohort were 
unable to reproduce itself for 2 or more consecutive years the result could be 
extirpation of the race. 

There have been substantial losses of fish and wildlife habitat associated with units 
of the CVP. Chinook salmon have been extirpated from the San Joaquin River and 
greatly reduced in tributaries to the San Joaquin River — an overall reduction of 
about 90 percent. Almost all of the Central Valley's emergent wetlands and woody 
riparian has been lost due to water development and agriculture. None of Central 
Valley national wildlife refuges have been acquired or are operated as CVP 
mitigation features. In spite of this migratory waterfowl have persisted in fair 
numbers although public refuges supply only about 15 percent of their wintering 
habitat The same can not be said for many wading, shore birds, and other wildlife. 
Central Valley woody riparian vegetation has been greatly diminished and not 
significantly mitigated. Untold numbers of migratory song birds and raptors have 
been lost in direct proportion to their habitat loss. All told, a vast array of 
migratory birds, anadromous fish, and resident fish and wildlife habitat and 
populations have been lost. 

These losses can never be replaced given the present conditions in the Central 
Valley, but partial replacement is in order. For wetland and riparian dependent 
wildlife and stream dependent fish the key resource for habitat compensation is 
water — water supply for wetlands and riparian areas and instream flows for fish 
and other aquatic life. Without water, compensation is impossible. If these 
resources ai-e to be in any way mitigated, water in significant quantities must be 
set aside for these purposes. The self imposed Departmental moratorium on CVP 
contracting should be continued until fish and wildlife needs are resolved. Jointly 
our two agencies, should be able to achieve such a resolution but not if needed firm 
water supplies are no longer available. A self imposed and jointly supported 
moratorium is a good administrative fish step to solving these fish and wildlife 
problems. I ask your support sind assistance in seeking it 

RECOMMENDATIONS 



The Fish and Wildlife Service therefore recommends that for mitigation of the 
impacts of the COA: 

1. Multiple-level intakes to the outlet structures at Clair Engle and Shasta 
Lakes be provided to allow the best possible control of water tempera- 
ture for protection of downstream fisheries. 

2. Until multiple-level intakes to the outlet structures at Shasta and Clair 
Engle Lakes are in operation, storage be held at levels sufficient to 
assure that release water maintains the temperature in downstream 
reaches utilized by salmon for spawning and egg incubation at or below 
56°F. 



68 



19 



And in furtherance of a 1978 Secretarial decision to conserve fish and wildlife 
resources and specifically provide a guaranteed water supply to Central Valley 
national wildlife refuges, the Fish and WQdlife Service recommends: 

3. Minimum flows from the Folsom Project to the lower American River 
be set at: 

a. No less than 1750 cubic feet per second from Nimbus Dam to the 
Howe Avenue Bridge from October 15 to December 31, for 
spawning salmon; 

b. No less than 1250 cubic feet per second from Nimbus Dam to the 
Howe Avenue Bridge from January 1 to March 31, for salmon 
incubation and rearing; 

c. No less than 1250 cubic feet per second from Nimbus Dam to the 
mouth of the American River from April 1 to June 30, and such 
additional flow as may be required to prevent water temperature 
at the mouth of the American River from exceeding 65 F, for 
salmon rearing and out-migration; 

d. No less than 800 cubic feet per second from Nimbus Dam to the 
mouth of the American River from July 1 to March 31, for all 
fishery purposes. 

4. At least 60,000 acre-feet of water be reserved in Folsom Reservoir for 
release at the direction of the fishery resource agencies during the 
period October 15 to June 30 to facilitate upstream and downstream 
migration of salmon. 

5. The minimum flow to the Sacramento River at Keswick be set at 6,000 
cubic feet per second pending the results of a 2-year study of the 
relationship of river flows to fish habitat in the river. (The results of 
the flow study, presently being undertaken by the California Depart- 
ment of Fish and Game, will provide the basis for setting long-term 
minimum flows for protection of the fishery.) 

6. A firm annual surface supply of 211,00 acre-feet of Class 1 water be 
furnished, on a non-reimbursable basis, to Central Valley national 
wildlife refuges. 

7. A firm annual supply of 246,000 acre-feet of Class 1 water be 
furnished, on a non-reimbursable basis, to the Grasslands Resource 
Conservation District and Butte Sink Area to serve Migratory bird 
needs. 

8. A firm annual supply of 78,000 acre-feet of Class 1 water be furnished, 
on a non-reimbursable basis, to the State of California's Los Banos, 
Mendota, and Gray Lodge Wildlife Management Areas. 



20 

69 



9. A firm supply of power be provided, on a non-reimbursable basis, to 
Central Valley national wildlife refuges, State waterfowl management 
areas, and to Coleman National Fish Hatchery. 

10. No further contracting of CVP firm supply for agricultural, municipal 
or industrial uses be undertaken until all fish and wildlife needs 
associated with the CVP have been identified, resolved, and solutions 
authorized. 



" 



>ATt Of CAlffOtNU— TWC WSOUtCtS AGINCr GtO« Ge OeUKMtllAN. 

[EP^RTMENT OF FISH AND GAME 
U NINTH SHEET 
aUMCKTO. CAUFOKNU «9il4 

(916) 445-3531 



October 17, 19R5 



Mr. James J. McKevitt, Field Supervisor 
U. S. Fish and Wildlife Service 
Division of Ecological Services 
2800 Cottage Way, Room E-1803 
Sacramento, CA 95825 

Dear Jim: 

We have reviewed your "Detailed Report on the Central Valley 
Project/State Water Project Coordinated Operation Agreement," 
preoared in compliance with the Fish and Wildlife 
Coordination Act. The report is a fine summary of fish and 
wildlife problems. We would, however, have preferred a 
document which, aside from the broader issues related to the 
marketing of water, distinguished more clearly the relativelv 
small effects of the Coordinated Operation Agreement (COA) 
from the ongoing impacts of the Central Valley Proiect (CVP). 

As you know, we consider our joint responsibilities under the 
Fish and Wildlife Coordination Act to be of paramount 
importance to protecting public trust and interest in fish 
and wildlife resources. It is clear to us that the intent of 
the law is that we each provide the Secretary of the Interior 
and the Congress of the United States a comolete analysis of 
the probable impacts of a prooosed project or modification of 
an authorized project and recommendations which are as 
specific as practicable for measures to mitigate or 
compensate for identified damages to fish and wildlife. In 
the instance of this particular report, we also share the 
responsibility of carrying out the 1978 directive of the 
Secretary of the Interior wherein we were asked to identify 
the instream flow needs in the areas of origin and to clarify 
the requirements for water at the Central Valley wetlands. 

The Bureau of Reclamation, the Department of Water Resources, 
ourselves, and your agency have worked together to identify 
the most effective and economical means to solve these fish 
and wildlife problems associated with the construction and 
operation of the CVP and State Water Project (SWF). We 
believe the Secretary and Congress require the benefit of all 
our conclusions and recommendations. To that end, we offer 
the following comments; 




71 



-2- 



1. In your presentation on "Resources without the Project 
for the Central Valley" you point to current planning and 
hoped for improvements. It is important to point out 
that the problems that are being studied are those caused 
primarily by the operation of the CVP. Further, funding 
for these studies, under the "Central Valley Fish and 
Management Study" is sponsored by the Bureau of 
Reclamation. The various studies are in several 
different stages of the Federal planning process. They 
all share one common constraint; in order for the 
corrective measures to be implemented, congressional 
authorization is required. Your report should reflect 
the uncertainty associated with this requirement and the 
probability of conflict if the remaining yield of the CVP 
is contracted under the COA. 

2. In your discussion of resource categories, we suggest you 
add spring-run Chinook salmon to category 1. 

Impacts resulting from lack of spawning flows, lost 

gravel recruitment, high water temperatures, pollution, 

and barriers to migration have driven this run to near 
extinction. 

3. In evaluating potential fish and wildlife imoacts 
associated with water marketing under the COA, we must 
recognize that the aunount, method, and timing of 
transport of marketed water could have far-reaching 
impacts on fish and wildlife. For examole, the levels of 
reservoirs, the magnitude of their fluctuation and the 
temperature of water released downstream could be 
affected. In the Sacramento-San Joaquin river systems 
toxic materials may be insufficiently diluted (coooer and 
zinc from Spring Creek), introduced (selenium from 
agricultural drainage) , or insufficiently flush out as in 
the case of sand and silt on the Trinity River. Higher 
flows for irrigation deliveries could indirectly impact 
salmon by increasing the demand for more ripraoping for 
bank protection. Nonstructural, operational solutions to 
fish passage at Red Bluff Diversion Dam could be 
impacted. Flow changes may also affect riparian zone, 
floodplains, and land use to the detriment of fish and 
wildlife . 

Your analysis focuses almost entirely on probable impacts 
during critically dry years. It should be recognized 
that the COA, the current operation of the CVP, and 
future conditions, if more water is marketed, 
significantly restrict the opportunity of fish 
populations to take advantage of near optimal conditions 



72 




UNITED STATES DEPARTMENT OF COMMERCE 
National Ocaanie and Atmoapharle Adminiatration 

NATIONAL MARINE FISHERIES SERVICE 

Soutnwest Region 

300 South Perry Street 

Terminal Island, CA 90731 o 

October 3, 1985 j */SWR33*RfiCW- 

• ; Ad--:- 

Mr. Richard J. Myshak j ?"-[;' 

Regional Director I y^.^v ^^,^,♦ 

0. S. Pish and Wildlife Service .^... a^-i 

500 N.E. Multnomah Street, Suite 1692 ^:c. Sv:;. 

Portland, Oregon 97232 



Dear Mr. Myshak: 



I am responding to Jim McKevitt's 9/25/85 request th^ 



orrt 

views concerning your Pish and Wildlife Coordination Ac^ R eport 
on the Coordinated Operation Agreement (COA). The COA would make 
possible more efficient operation of the Pederal Central Valley 
Project (CVP) and the State Water Project (SWP). However, the 
coordination of water projects as specified in the COA would also 
have adverse impacts, if unmitigated, on salmon spawning and 
rearing in the upper Sacramento, American, and Trinity Rivers, 
and in San Prancisco Bay. In general, we support your 
Coordination Act Report and concur in its conclusions and 
recommendations. We do think it would be appropriate to mention 
some of the past dissatisfactions the various resource agencies 
have stated regarding existing Decision 1485 water standards 
referenced in the text of the Report. 

The coordination proposed in the COA is laudable. However, 
as you know, the relationships involved in this coordination are 
extremely complex, both for the operation of the water projects 
per se, and for the fish and wildlife that rely on Central Valley 
habitats. The Secretary of Interior recognized this, when he 
adopted Option 6 of the 1978 Decision Document. That decision 
made it clear that the Department of Interior intended to, among 
other things, implement a COA between the United States and the 
State of California. It also made clear the Department's 
intention to provide that: 

"conservation and development of fish and wildlife 
resources, and maintenance of the quality and quantity of 
all waters affected by the project, including the estuary, 
are authorized purposes of the CVP...with the objective of 
maintaining fish and wildlife at recent historical (1922- 
l9b/) levels, and that equal consideration be given to fish 
and wildlife in the development and allocation of any new 
water supplies, and that all costs for such water be 
non-reimbursable. " 



(|%) 



73 



The Icey element in maintaining the quality and quantity of 
anadromous fish habitat in the Sacramento-San Joaquin system is 
understanding clearly the relationship between flows and fish 
production. No comprehensive evaluation of fishery instream flow 
needs has been attempted - although the California Department of 
Fish and Game (CDPG) has just begun such a study. In addition, 
NMFS has just entered into a contract to develop a fish-flov- 
economics modeling tool to evaluate the value of Sacramento Piver 
flows for Chinook salmon production. These evaluations should 
provide the basis for defining the flow regime required to 
protect the "quality and quantity" of anadromous fish habitat in 
the Sacramento River system. 

Thus we see the COA and establishment of adequate fishery 
flows as part of a comprehensive approach to equitable solution 
of these issues. The COA does not in itself develop new water 
supplies, but it certainly facilitates diversion of additional 
water from the system. Consequently, we strongly support the 
mitigation measures discussed in your report. In addition, we 
urge the Department of Interior to incorporate into a 
comprehensive solution 1) a flow regime based on the results of 
CDFG's instream flow evaluation, 2) the tools to be developed in 
our salmon habitat valuation study, and 3) a complete 
reassessment of the adequacy of past CVP mitigation in the upper 
Sacramento River. 

I believe we are at an important crossroad in the course of 
anadromous fisheries in the Sacramento River system: 

the CDFG fishery instream flow need study, 

the NMFS contract for "Determination of the Value of Chinook 
Salmon Habitat in the Sacramento River," 

the reopening of D1485 standard hearings, thereby allowing 
existing inadequacies to be addressed, 

- the development of the COA, and 

- efforts to develop a comprehensive salmon management plan in 
the Sacramento River system. 

Consequently it is important, now more than ever, that all 
of us ensure that our actions and recommendations are carefully 
crafted and do not preclude addressing the complex fish and 
wildlife, and water problems in a sound, comprehensive manner. 



74 



-3- 



which would normally occur absent the large-scale 
diversions by the CVP. The proposed marketing will 
reduce the freguency and duration of such population 
rebuilding opportunities. 

Existing law (D1485) regulates only the salinity in the 
San Joaguin River system relative to water diversion at 
the Delta. If the COA facilitates greater ratios or 
longer duration diversion rates at the Deltar it will 
result in increased entrainment and loss of juvenile 
salmon. Hopefully, agricultural drainage flows to the 
San Joaguin River will be decreased in the future and the 
salinity standards will be less important. However, a 
positive downstream flow sufficient to transport 
outmigrant salmon past the pumps and through the Delta is 
essential to the recovery of the San Joaguin system 
populations. This issue should be studied and 
recommendations should be prepared. 

Relative to your specific recommendations: They are 
similar to those which we intend to make at the time it 
is proposed that any water made available by the COA is 
to be marketed. We expect the current studies being 
conducted by your agency, the Bureau of Reclamation, and 
ourselves to be completed soon. We will be in a position 
to clearly identify the most effective and efficient 
means available to solve the currently unmitigated fish 
and wildlife problems caused by the CVP. 

Your recommendation that no further contracting of CVP 
firm supply be undertaken until fish and wildlife needs 
have been identified and solutions authorized is 
particularly important. If, for example, the Secretary 
of the Interior chooses to continue the current 
moratorium on contracting CVP water until fish and 
wildlife issues are resolved, it would be one way of 
ensuring consistency with the position of our Department 
on the COA, a position we expressed to Congressman Miller 
in June of 1986. It is our intent to focus on the water 
marketing plan and its authorization as the point where 
fish and wildlife impacts of the entire CVP will be 
addressed and resolved. 

It is our understanding from discussion with Department 
of Water Resources, Bureau of Reclamation, and others 
that congressional approval of the COA will not preclude 
these considerations for fish and wildlife at that time. 

Under the California Environmental Quality Act and the 
National Environmental Policy Act both the State and 
Federal water development agencies will be reguired to 



75 



-4- 

fully disclose the environmental impacts of not only the 
current change in the orojects but with the earlv 
construction and ongoinq ooeration. If these impacts are 
to be mitigated, yield of the projects must be available. 

We appreciate this opportunity to comment. We believe that 
implementation of your recommendations will move us all 
forward toward eventual restoration of fish and wildlife. 

Sincerely, 

irneir ^■*— 




cc: Department of Water Resources 
U. S. Bureau of Reclamation 



76 



Thank you for the opportunity to review and comment on your 
report. 

Sincerely yours, 

E. C. Fdllerton 
Regional Director 



cct CDPG, D. Lollock 
FWS, J. McKevitt 



77 



FT P 1 ^ 1986 



78 



MP-780 



To: Regional Director, U.S. Fish and Wildlife Service, 
Portland, OR 

Fromj^jJiJ^^egional Director, Sacramento, CA 



^■y^t^' 



Subject: Review of Coordination Act Report on Coordinated Operation 
Agreement 

We have reviewed the subject Report on the Coordinated Operation Agreement 
(COA) and our position is as follows. 

As we have stated before, we share your commitment to resolve the issues 
and the real problems facing the fish and wildlife resources within the 
Region. However, the COA is not, nor is any other single project or 
proposed action, the suitable vehicle to record and attempt to resolve 
all the fish and wildlife problems in the Central Valley. A response 
such as your final Coordination Act Report tends to cloud and confuse 
the issues if not outright mislead the reviewing public. 

On September 25, 1985, you transmitted to me a draft memorandum and 
draft detailed report describing the effects of the COA with recommenda- 
tions for mitigation. We provided comments on that report to you on 
October 10, 1985. On November 21, 1985, I received a revised memorandum 
and detailed report. In that memo you suggested I contact you by 
November 25, 1985, if I should continue to have oroblems with the 
contents of your report. Unfortunately, there was not enough time to 
provide you with a complete and thorough review of your revised report. 
Through our ensuing review we have determined that your revised final 
report has adopted numerous Bureau of Reclamation (BOR) comments, but 
your recommendations remain largely unaffected. 

The Fish and Wildlife Service's (FWS) recognition of the impacts related 
only to the COA as opposed to those impacts of the existing and future 
segments of the Central Valley Project (CVP) is obvious by your method 
of presentation of impacts in separate categories. However, you still 
insist that all the impacts are COA related. For example, the inclusion 
of your new recommendation no. 10 and your distinction between COA-r elated 
impacts and "activities inseparably related to the COA" may only reflect 
a major policy dichotomy between BOR and FWS. I hope we can build a 
trust level that will allow us to resolve many of the issues that now 
confront ua. 



/?} 



p, 7?0 



We have consistently Indicated the COA should not be held accountable 
for impacts that may be related to future use of project water. Addi- 
tional actions (includinq environmental review) must be completed 
before future water commitments can be made; these additional actions 
will address the respective project impacts. 

The COA provides for protection of water quality in the Delta as set 
forth in Exhibit A which was extracted from D-1485. Implementation of 
the COA will allow the BOR and Department of Water Resources (DWR) to 
coordinate the operation of the CVP and the State Water Project (SWP) in 
a manner that allows more efficient use of water supplies and facilities 
of both projects. The CVP water supplies identified in the COA will be 
used to meet the multiple purposes of the CVP to the maximum extent 
practicable. The COA does not create water for the CVP or allocate CVP 
water to any particular use or uses. 

Your report assembled the recommendations into two cateaories. One 
category pertained to COA impact mitigation while the other category 
pertained to "activities inseparably related to the COA (i.e. . through 
the umbrella of the Secretary of Interior's Decision Document on Opera- 
tion of the Central Valley Project, California, to Meet Water Quality 
Standards for the Sacramento-San Joaquin Delta, dated December 29, 
1978)." Only two actions are recommended for mitigation of the COA - 
multiple-level outlet facilities at Clair Engle and Shasta Lakes and, 
pending construction of these facilities, maintenance of sufficient 
water storaqe at these two reservoirs to ensure temperature protection 
for salmon downstream from the dams. The remainder of the actions 
relate to the protection language in the referenced secretarial decision 
document. 

Generally, your Report does not provide sufficient justification of 
recommendations, identification of authoritative sources of information 
(i.e., literature references, expert opinion sources), quantification of 
impacts, and explanation of cause and effect events. To meet the 
requirements of the Fish and Wildlife Coordination Act, the Report must 
be revised and include only those impacts attributable to the COA. The 
text must overcome these deficiencies. In its present form the Report 
is deficient in describing the consequences of the proposed actions. 
Details on significant fish species are lacking. Names of affected 
species, their respective life cycle requirements, and habitats should 
be discussed. 

The following presents a detailed response to each recommendation. 

Recommendation No. 1 

Multiple-level intakes to the outlet structures at Clair Engle and 
Shasta Lakes be provided to allow the best possible control of water 
temperature for protection of downstream fisheries. 



79 



Response No. 1 

Clair Enqle Lake 

COA impacts on Trinity River temperatures due to greater Clair 
Enqle Lake drawdowns in dry and critical years are discussed in the COA 
Draft Environmental Impact Statement/Environmental Impact Report (DEIS/ 
EIR) - paae 78. Temperature warming was found to be significant (2^ 
or more) in only 3 years out of 82; minor (1°F) in 2 years; and 
non-existent in the remaining 77 years in the 1980 level studies. Minor 
impacts occurred in only one year in the 2020 level studies. 

Multilevel outlets (MLO) for Trinity Dam (Clair Engle Lake) 
were evaluated in a 1979 BOR study for the Trinity River Basin Fish and 
Wildlife task force.* Preliminary cost estimates ranged from $9 to $30 
million depending on the type of structure. The study determined that 
Trinity Dam MLOs would benefit fisheries in the spring and fall months 
by providing warmer temperatures downstream from Lewiston Dam. The 
ability of MLO to mitigate COA impacts by providing cooler temperatures 
in critical, low storage years was not evaluated, however. 

Studies are currently underway by DWR, Department of Fish and 
Game (DFG) , and BOR to evaluate means of controlling release temperatures 
to the Trinity Hatchery with structural modifications at the Clear Creek 
Tunnel intake (curtain) and the Lewiston Dam Hatchery supply intake 
(skimmer). Temperature control of releases to the Trinity River may be 
possible with similar modifications to Lewiston Dam at a much lower cost 
than Trinity Dam MLO. 

Shasta Lake 

COA impacts on Sacramento River temperatures due to greater 
Shasta Lake drawdowns in dry and critical years are discussed in the 
DEIS - pages 74-77. Significant warming was found to occur in only 3 
out of 83 years, minor impacts in 2 years, with no impact in the remaining 
77 years. 

The feasibility of multilevel intakes at Shasta Dam for 
controlling Sacramento River temperatures is being evaluated in the 
Central Valley Fish and Wildlife Management Study - Problem C-2, The 
report is scheduled for completion during the summer or fall of 1986. 
Preliminary results of C-2 math model studies indicate overall reductions 
in temperature-related salmon mortalities ranging from about 2% to 6% 
depending on type of year. Cost estimates of Shasta MLO range from 



*Rowell, J. H. ; "Mathematical Model Investigations, Trinity Dam ■" Multilevel 
Outlet Evaluation, Trinity River Temperature Prediction Study"; Trinity 
River Basin Fish & Wildlife Task Force - Interim Action Program; U.S. 
Bureau of Reclamation, Sacramento, CA; May 1979. 



about $10 to 30 million. The averaqe annual cost per salmon saved was 
eBtimated to be about $1300 for the most cost-effective MLO alternative 
evaluated. 

Shasta MLO temperature benefits to salmon appear to be marginal 
in most years, and even less effective in critical years (i.e., 1933) 
when cold water availability in Shasta Lake is depleted during severe 
drawdown. 

It would be fiscally and technically irresponsible for the BOR to 
recommend to Congress MLO facilities at Clair Engle and Shasta Lakes 
when costs are high and effectiveness marginal and even less effective 
in the driest years. However, we should wait for the study results 
before making any further recommendations. 

Recommendation No. 2 ■ ' 

"...storage be held at levels sufficient to assure that release 
water maintains the temperature in downstream reaches utilized by salmon 
for spawning and egg incubation at or below 56°?." 

Response No. 2 

COA temperature impacts related to Shasta and Clair Engle Lake 
storages occur in only dry and critical years (5 out of- 82). Downstream 
temperatures without the COA during these years exceed 56°?, as well 
as with the COA. Therefore, this recommendation has no bearing on COA 
impact mitigation. With or without the COA, it would be physically 
impossible to meet this criteria in many years, particularly dry and 
critical years, given the demands on the CVP-SWP in the Delta and 
elsewhere. 

Recommendation No. 3 

Minimum flows from the Folsom Project to the lower American River 
be set at: 

a. No less than 1750 cubic feet per second from Nimbus Dam to the 
Howe Avenue Bridge frcm October 15 to December 31, for spawning 
salmon; 

b. No less than 1250 cubic feet per second from Nimbus Dam to the 
Howe Avenue Bridge from January 1 to March 31, for salmon 
incubation and rearing; 

c. No less than 1250 cubic feet per second from Nimbus Dam to the 
mouth of the American River from April 1 to June 30, and such 
additional flow as may be required to prevent water temperature 
at the mouth of the American River from exceeding 650F, for 
salmon rearing and out-migration; 



81 



<3. No less than 800 cubic feet per second from Nimbus Dam to the 
mouth of the American River from July 1 to March 31, for all 
fishery purposes. 

Resp)onse Nos. 3a, 3b, 3c, 3d 

Recommendations 3a, 3b, 3c, and 3d were presented in an earlier 
report (FWS 1985) identifying the flow needs of chinook salmon in the 
American River. The FWS prepared this earlier report under contract 
with the BOR as a part of the BOR's Auburn-Folsom South Unit studies 
which are associated with the development of Auburn Dam. The flow 
recommendations were derived from an Instream Flow Incremental Methodol- 
ogy study for use by the BOR in the reauthorization of the Auburn-Folsom 
South Unit. The BOR participated in the instream flow studies in 1981 
and reviewed the analysis and subsequent report. 

The BOR is presently obligated to provide flows in the American 
River as defined in State Water Resources Control Board Decision D-893 
relative to the Folsom Project. This decision resulted from an agreement 
between the BOR and DFG in 1957 on the fishery and other needs in the 
American River. 

The BOR recognizes that the flows in D-893 are less than desired, 
but we disagree that the Folsom Project authorization should be revised 
to accommodate higher flows. The BOR supports development of an increased 
flow regime which will be developed in the Auburn-Folsom South Unit 
study; this increased flow regime would be provided by Auburn Dam and 
Reservoir. 

Relative to your recommendation 3c in particular, the COA tempera- 
ture impacts are minor and occur in only 2 out of 82 years. This 
recommendation, therefore, has little or no relationship to mitigation 
of COA impacts. Lower American River temperatures are dependent on 
Nimbus release temperatures and climatic conditions as well as flow. 
With typical Nimbus temperatures, flows required to maintain 650f at 
the mouth during April-June have been estimated to range from less than 
500 to about 9,000 cfs depending on air temperature conditions. This 
wide range of required flows, along with the other factors influencing 
river temperatures, would make it difficult, if not impossible, to 
implement this recommendation. 

We feel the reauthorization of the Auburn Dam-Folsom South facilities 
is the proper vehicle for developing revised flows for the American River. 

As you may know, there currently is litigation related to the flow 
requirements of the lower American River and there are efforts under the 
auspices of Sacramento County to establish an adequate flow regime. 
Both of these activities could be important factors in developing an 
acceptable solution to what has been a long standing issue. These 
issues are important to the BOR but are totally unrelated to the COA. 



82 



Recommendation No. 4 

At least 60,000 acre-feet of water be reserved in Folsom Reservoir 
for release at the direction of the fishery resource agencies during the 
period October 15 to June 30 to facilitate upstream and downstream 
migration of salmon. 

Response Ko. 4 

Same as response to Recommendation Nos. 3a-3d. 

Recommendation No. 5 

The minimum flow from the Shasta/Trinity project to the Sacramento 
River be set at 6,000 cubic feet per second pending the results of a 
2-year study currently being undertaken by the DFG on the relationship 
of river flows to fish habitat in the river. 

Response No. 5 

There is an agreement between the BOR and DFG, signed in 1960, 
which defines minimum flows to be maintained by CVP facilities in the 
upper Sacramento River. The BOR, under the Central Valley Fish and 
Wildlife Management Study, is presently evaluating several alternative 
flow regimes expressly for salmon in the Sacramento River. Personnel 
from the BOR, DFG, and FWS are participants on the planning team that is 
evaluating these flow alternatives. Computerized mathematical model 
studies will be performed to evaluate the impact on CVP operations. 
Water temperature conditions on the river that will occur as a result of 
these flow regimes will be evaluated to identify the impacts on salmon. 
Reservoir fisheries impacts will be evaluated to determine the impacts 
resulting from these flow regimes. 

We understand DFG is currently heading an instream flow incremental 
methodology study to identify the salmon flow requirements in the 
Sacramento River. DFG's effort will collect and analyze hydrological 
and biological field data for use in developing fish flow criteria and 
is unrelated to the COA. 

Pending the conclusion of the BOR and DFG studies, we feel the 
establishment of interim flow criteria is premature. We support the 
need to develop criteria based on sound data developed through a well- 
designed program. We are unaware that such data exist. We therefore 
cannot support any changes at present to the flows contained in the 1960 
agreement. 



83 



Recommendation Nos. 6, 7, and 8 

6. A firm annual surface supply of 211,000 acre-feet of Class 1 
water be delivered to Central Valley national wildlife refuges 
on a nonreimbursable basis. 

7. A firm annual supply of 246,000 acre-feet of Class 1 water be 
furnished, on a nonreimbursable basis, to the Grasslands 
Resource Conservation District and Butte Sink Area to serve 
migratory bird needs, 

8. A firm annual supply of 78,000 acre-feet of Class 1 water be 
furnished, on a nonreimbursable basis, to the State of California's 
Los Bancs, Mendota, and Gray Lodge Wildlife Management Areas. 

Response Nos. 6, 7, and 8 

Providing additional water to wildlife refuges will not mitigate 
any negative impacts of the COA. Therefore, these recommendations 
should be deleted. As we previously stated, the COA would not by itself 
result in any new water contracts. Furthermore, any new contracts would 
not necessarily result in impacts to fish and wildlife by converting 
native vegetation to irrigated farmland. Most new contracts would, more 
than likely, go to already-developed lands with a groundwater overdraft 
problem. Also, the environmental impacts of such contracts will be 
addressed in other NEPA analyses. 

Your recommendation that BOR commit 535,000 acre-feet on a nonreim- 
bursable basis of firm CVP surface water supplies for uses in public and 
private wildlife management areas located in the Central Valley of 
California would require additional authorization beyond the approximately 
100,000 acre-feet now authorized to be furnished on a nonreimbursable 
basis to these lands. If these additional water supplies were to be 
furnished on a nonreimbursable basis, then the cost to the Federal 
Treasury, in terms of scheduled revenues foregone, could be as much as 
$810,000,000 during the remaining 45 years of the authorized repayment 
period associated with the existing CVP. 

The BOR is aware of the need for additional water supplies for 
Federal and State wildlife refuges in the Central Valley. Problem B-1 
of the Central Valley Fish and Wildlife Management Study is investigating 
this problem. The interagency team, of which the FWS is a part, is 
currently completing an appraisal-level study identifying problems and 
needs of the refuges. In addition, a two-year feasibility-level refuge 
water supply study began in October 1985. This study will identify 
sources of water and methods to deliver a firm supply of water of 
acceptable quality to each of the refuges, and to the Grasslands area. 



84 



ReconuT\endation No. 9 

A firm supply of power be provided, on a nonreimbursable basis, to 
Central Valley national wildlife refuqes. State waterfowl manaqement 
areas, and to Coleman National Fish Hatchery. 

Response No. 9 

Providing power is not relevant to any COA impacts, in a manner 
similar to the earlier discussion for water deliveries to wildlife 
areas. 

Whether or not we can provide project power to Coleman is 
a question we are trying to answer through other means. The COA is 
totally unrelated. 

Recommendation No. 10 

No further contracting of CVP firm supply for agricultural, munici- 
pal, or industrial uses be undertaken until all fish and wildlife needs 
associated with the CVP have been identified, resolved, and solutions 
authorized. 

Response No. 10 

The fish and wildlife issues you have raised are not a result of 
the COA. In fact, many of them may not even be a result of past activities 
related to the CVP. To recommend prohibition of further contracting 
pending resolution of such unrelated issues is inappropriate for the 
purposes of your Report and misleading to many of those who might review 
it. 

The following are specific comments on the text of the detailed Report. 

Specific Comments - Memorandum 

1. Page 1, last paragraph ; Your Coordination Act Report itself will 
be part of the total reporting package to acccanpany the DEIS/EIR. 

2. Page 2, first full paragraph ; Your Report may be brief and 
unsupported by field studies, but you have had several years to consider 
the potential impacts of the COA. The COA itself has changed little 
since the December 4 draft of 1982. The BOR and FWS negotiated in the 
fall of 1983 for appropriate evaluations related to the COA, and Letter 
of Agreement No. 12, signed by James W. Teeter, on December 8, 1983, was 
the result. Likewise, many of your recommendations are in the DEIS/EIR. 
They were received on January 4, 1984, and are located under Appendix C, 
Consultation and Coordination. 



85 



Specific Comments - Detailed Assessment 

1. Page 1> paragraph 2, sentences 5 and 6 ; Your Report should be 
reviewed for possible revision, since a later draft EIS/EIR (July 
1985) is available than the draft identified in this report. 

2. Page 3 ; We recommend that the Report delete all lines beginning 
with "Article 1, Preamble" and ending with "Exhibit E, Water Shortage 
and Apportionment." The deleted text appears to be unnecessary because 
it does nothing to aid the reader in understanding the COA operation. 

3. Page 4, second full paragraph ; Interim water is, in essence, 
discussed here. Intermittent is academic since the CVP would be 
operated to meet D-1485 in all but dry years. 

The no-action operation studies used are appropriate. Due to power 
operation and flood control operations, D-1485 is normally or even 
incidentally met in all but dry and critical years. 

4. Page 5, first full paragraph, sentence 2 ; There are numerous 
references in the report to the Secretary of Interior's Decision 
Document on Operation of Central Valley Project, California to Meet 
State Water Quality Standards, dated December 29, 1978. We recommend 
the document be properly cited as such and that a brief explanation of 
at least Option 6 be included. 

5. Page 8, paragraph 3, sentence 3 ; This sentence is misleading and 
confusing. The information presented will only be understood by scientists 
or people with previous exposure to striped bass problems in the Delta. 
The significance of the index must be defined, as a minimum. 

6. Page 8, paragraph 7; and page 9, paragraph 1, sentences 1 and 3 ; 
The quantitative and qualitative information that exists on waterfowl 
should be presented (summarized, if appropriate) and/or referenced 
properly. 

7. Page 9, paragraph 5 ; BOR maintains estimates on angler use in CVP 
reservoirs. This information is available and should be included in 
this paragraph. 

8. Page 12, paragraph 1, sentence 9 : The statement "loss of salmon in 
other types of water year has not been estimated." This statement 
implies there may be temperature-related salmon losses in years other 
than critical and dry years. The studies found no impacts in other 
years (77 our of 83). Of the six critical and dry years, only three 
were found to have significant temperature impacts (greater than 1°F) . 

9. Page 12, paragraph 3, sentence 2 : The implication that there could 
be significant temperature impacts in "16 out of every 600 months" on 



86 



American River fisheries does not agree with the temperature study 
results. Minor temperature impacts of about .5-1°F were found in only 
8 months out of 83 years (996 months) at the 1980 level. No impacts 
were found at the 2020 level. 

10. Page 18, item 2, sentence 3 ; The Report does not identify which 
life stages of salmon are affected by temperatures in the 56-62°? 
range. In addition, the type of exposure that results in mortality 
(duration of continuous exposure, frequency of exposure, etc.) should be 
discussed. Further, the Report should identify whether the vulnerable 
life cycle stages are present when expected high water temperatures 
would occur. 

Conclusion 

The BOR, with assistance from the FWS, DFG, and many other agencies, 
organizations, and individuals, has been working to resolve many of the 
fish and wildlife resource problems described in the Report for many 
years, and will continue to work towards their resolution. However, the 
BOR will not support unfounded conclusions leading to unsuitable recommen- 
dations. The problems facing the fish and wildlife resources are many 
and varied, and the solutions, it would seem, are even more complex. My 
personal perspective is that we should try to build consensus on as many 
issues as we can afford, with as many beneficiaries as can reasonably be 
expected, and which corrects as many of the fish and wildlife problems 
as we can foreseeably correct, but which avoids unreasonable sacrifices. 

In the future, building consensus will be the key ingredient to protecting 
the fish and wildlife resources rather than confrontation. We look 
forward to working with you in pursuit of that objective. 



BSchroedertcd 1/10/86 
Retyped: 1/29/86 



87 



Section 3. COMMENT LETTERS AND TRANSCRIPTS OF PUBLIC MEETINGS 



{mj 



m 



UNITED STATit CNVMOMMENT Al PflOTf CTION AOENCV 



■m fnmflmm. Ca. MIM 



•ob Schro*d«r 

U. 8. turvau of MaclMiatlon 
2«00 Cott»g« Way, Kooa M-2117 
tacraBanto, CA tStSS 

Daar Nr. Schroadan 




a^n-i^" 



Tha Bnvirona«ntal rrotactlon Agancy (BPA) has ravlawad 
tha Draft BnvlroiwanCal lapact Stata«ant/ltaport (DCIS/K) tltlad 
COORDtHATED OPBItATIM ASSKBMBIfT, CBimua VALLBT P«OJBCT/8TATB 
UATBR PBOJECT. 

Tha BnvlrofMantal Protactlon Agancy atrongly aupporta 
tha davalopaant of a Coordinatad Oparatlon Agraaaant batwaan 
tha Cantral vallay Pcojact and tha Stata Matar Projact. Tttla 
will anabla tha two projacta to oparata aora aCficlantly, whlla 
aaaurlng that aach pro)act ahara In tha raaponalblllty to 
protact tha banaficlai uaaa of tha kay/Oalta aatuary. 

Ma hava claaalfiad thla DCX8/I aa Category BC-l, Environ- 
•antal Concarna - Inautflclant Information (aaa attachad 
"Bu^ury of Rating Daflnltlona and Pollow-Dp Action"). TMa 
DKI6/R la ratad BC-2 bacauaa ofi 1) tha lack of eo^ltaant to 
fully »aat currant watar quality atandarda (8ulaun Harah atan- 
darda), and 2) tha naad to outllna a procadura by which futura 
watar quality atandarda will ba raviawad for conalatancy with 
Congraaatonal dlractlvaa. Nora datallad co^Mnta ragardlng 
our concarna ara ancloaad. Tha claaalf Icatlon and data of 
BPA'a coaaanta will ba publlahad In tha Padaral Ragiatar In 
accordanca with our public dlacloaura raaponalbllltlaa undar 
Sactlon 309 of tha Claan Air Act. 



^ 



m .- 



Wa appraclata tha opportunity to ravlaw thla DCIS/R. 
Plaaaa aand 3 coplaa of tha Pinal Bnvlronaantal lapact Stata- 
aant/Raport (PBI8/B) to thla offlca at tha aaaa tlaa it la 
officially filad with our Haahlngton. D.C. offlca. If you 
hava any quaatlona* plaaaa contact Nr. Brian McKaown, Matar 
nanagaaant Divlalon« at <41S) 974-82B( or PTB 4S4-B2e«, or 
Ha. Hobarta Blank, Padaral Aotivttlaa Branch, at (41)) •74- 
•IBT or PTB 454-B187. 

■iBoaraly youra. 



■aolosuro () pagoa) 



Charlaa M. Hurray, Jr. (\i 
AABlatant Haglonal AtelnlArator 
for Policy aiMl Nanagaaai^ 



Barl Mlnfclar. CalKornU Oapartaant 
of Matar Raaourc«a 



m 



m. 



Matar Quality Co—tnta 

1. Ragardlng coaplianca with tha Bulaun Harah atandarda, p*g« 
24 of tha DCI8/B atataai 

Tha poat-1984 atandarda for Bulaun Harah wara not 
includad in Bahiblt A bacauaa It waa agraad by tha 
Dapartaant and tha buraau that tha Agraaaant would 
eontaaplata aalatlng facllitiaa only. Alao, nago- 
tlatlona concarning protaction of Bulaun Harah wara 
procaadlng aaparataly, ao tha Harah waa consldarad a 
aaparata laaua. 

Ma (Ind tha rationale that coaplianca with tha atandarda 
la tlad to tha conatructlon of angin*arad facllitiaa to ba 
unaupportabla. During tha Bacond Trlannlal Ravlaw of tha 
Dalta Plan, tha Btata Board aada It claar that coaplianca 
with Suiaun Harah atandarda waa aandatad aa of October 1, 
19B4, "through whatavar aaana ara available to tha projacta. 
Bpecitically, Page V-12 of tha AppandlB to the Delta Plan 
atataai 

Conaaquently. aoditlcationa have been aade reluc- 
tantly in tha plan eitending the coaplianca data 
(or full project eltigatlon of tha Harah to October 
1, 1984 and incraaalng interie Harah protection 
in dry and critical yeara. The project oparatora 
ahould not view thla data aa a target to ahoot for, 
but aa a date by which full altlgation will be 
required through whatever aeana are available to the 
projecta. 

Therefore, the Bulaun Harah atandarda ehould be included in 
Eshiblt A. 

2. Article 11 of the Coordinatad Operation Agraaaant coaalta 
the USSR to coaply with future watar quality atandarda if 
they ara not Inconaiatent with Congraaalonal dlractlvaa. 
However, the DBI8/R doea not apall out the Congraaalonal 
directivea which auat be coapliad with and how the detera- 
Inatlon of conalatancy will b0 aada. Tha PEI8/R ahould 
outline tha procadura tha D8BR will utiliie to dataralne 
if thaaa new atandarda are conaiatent with Congreaalonal 
directivea. 



It hAB alwaya been BPA'a poeitton that the a. 8. Bureau of 
Baclaaatloa (D8BR) la required to aeet Dalta watar quality 
•tandarda nader the authority of Bectlon 313 of the Clean 
Hater Act. The Dalta Hater Quellty Control Plan <D-14BS} 
eatabllabed Btate water quality etandarda which are Pederally 
approved, to ooatrol and abate water pollution (aalt watar 
intcvelon). Aa PBXB/B should addreaa tha DSBR requireaent 
to aeet current and future Delta water quality atandarda 
MAder eutkoricy of Bectlon )13 oC the Clean Hater Act. 

Page I oC the DSIB/R etateai 

Pederal legialation authorising tha Central Valley 
Project in 1937 declared that Ita facllitiaa "ahall 
be uaed flrat for river regulation, navigation and 
flood oontroli eecond for Irrigation and doaeatlc 
ueear and third for power.' Salinity control in 
the Delta *«a not apecltically listed aa a project 
purpose. 

■owever. la the recent California Buperior Court Daclaion 
en D-148S, Judge Plgone wrote. *thia court concludaa that 
the tera river regulation waa intended to Include aallnity 
and that aalinlty control haa a higher priority (or uaa 
than doea the esport of water for Irrigation.* Tharetora. 
the PBIB/R ahould apeelfically addraaa tha raalf Icationa 
of tha authorisation of the Central Vallay Project for 
regulation river of flows and the lapact on aalt watar 
Intrusion. 

Page 97 of the MIB/R ststeai 

After the Coordinated Operation Agreeaent le algned. 
the Bureau of Baclaaatlon plana to propoaa that 
the Secretary of tha interior lift a aoratoriua on 
tha Bureau entering Into additional long-tara CVT> 
water aervica contracta. Tha aoratoriua waa adain- 
latratlvely lapoeed by a previoua Secretary of 
the Interior in 1979. Tha tacaa of the aoratorlue 
provided that It would be lifted whan tha raaponsi- 
billtlea of the CVP toward watar quality protection 
in the Delta bad been clarified and tha Bureau had 
etsaitted Itaalf to aeet tbeae reaponalbll itles. 
Signing the Agreeaent would eoaalt the Bureau to 
aeeting theae reaponaibllltlaa. 

The terma of the aoratoriua required that tha reaponalbll 1- 
tlaa of tha CVP would first be clarified. It la BPA'a 
poaltion that thla haa not been fully accoapl lahed. Currently. 
there la no eoaaltaant to aeeting tha water quality atandards 
establlahed for the protection of Suiaun Harah. In addition. 



91 



@ 



th«r« la no protactlcM allooAtad to th« tMiMClclal uaaa of 
tan rraaclaco Kay. TUa Dalta Matar Ouallty Control rian 
baarlnga vlU opan In IXi, and could raault In tubataAtlal 
rairlalona to provlda protactlon for tan Pranclsco Kay. At 
this tlM. tKa Cvr haa not clarlflad how it «111 datanlna 
If futur* watar quality atandarda ara or ara not conalatant 
■1th Congraaalonal dlractlvaa. TIm Agraaaant doaa not 
outllna how thaaa tutura raaponalbll Itlaa vlll ba ^at. If 
additional watar contracta ara algnad. It ahould ba apaclflad 
that thaaa additional caaaltaanta do M>t taka pracadanca 
ovar flows that vlll ba r•<^llrad for protactlon of tha 
feay/Dalta aatuary. KTA atrongly ballvraa that thaaa laauaa 
aaad to ba fully raaolvad prior to aay e^Mltaant for 
looo-tacm vatar aarvica eontracta. 



m 



mmmm or ttaaa M f uuiuj* tm> loxcw-U' jicnw 

—riiwawril >yct ot tm i>ction 

U^—lM± at »jacticf» 

9m M iotUw^^ aot idMCUiad m^ irtantlal vwiroraantai u^^cta r«9ilrinu 
■HbBKMRlva ol^f^^a bo tJw prcvoaal. Hm ravlaw any ha«« dlacloaad cwacxtnltiaa 
tar ^(tllcackai ct mXX^^x,uxi — aaiaaa that ooiiH ba aon^JJahad vSth no man thar 
■ijBr I II am I to tha isTvaaai.. 

pp— »Pil i« »a nH J Cewemrnm 

Tm i^ twiaM haa klantlfiad awrtiiiM— ■! H^Mcca that Mould ba aaot^d 1a cx4ar 
to fully tawm tha mmrixiM^miL. Oarractlw* ^aaia'w aay ra^jira ctMi^^aa to Lh> 
Civa <v %9lli3ac.lai at aitioation aaaMvaa that oan raduoa tha 

■« Mould Uha GO Mork with tta iaad agancy to naaia thaaa 



Zsr^ 



K) »i>l i g— nf l CKnactlowe 

lb IK tmiam Imo IdvAlf lad ■ M^ l f li—a awrtii j — <i 1 l^Mcta that mm ba woldad 
la iji^i CO pBOVl^ rfirr*- ^ccactlon ter tha anvlroraant. OorracU«a Mia^ g i t «ay 
ragtfin ■<■!■< lal cMngaa to tha taataaiad altacnativa or aanaldaration at mcmm 
oumr pro^act altanMU** (IndulLno **» "D action altacnatlw or a aw altaraaUw). 
«* immaOt to work «1U tha iaad aoaoy to aMuoa thaaa lapacta. 

*-r*"* that ara at auftlciant 
■atpUtiili tJMt thay acv laaa* !■!■ uii ens t>ia m^m^oU*. at ptAlic haaith or 
^Uaa* cr aartcOHaNtal ^Allty. ■« Intama to wart with cha Iaad a^pncy to raduct 
thaaa Inpacta. If tha potawtlil i— atlafartrry l^acta aca mX oomctao at tha final 
KZB ac^^. thla prapoaal wUi ba laaaBHiidid lor taCarral to tha CSQ. 

jMaqjacy oi tha >gact ptataaanr. 

^taaory 1 *rtaijiata 

Va ballavaa tha «att KU Maijaiili aau terth tha amlmaanLal l^iactU) at 

,l«a ma thaaa of tha altamatlwaa raaaoniCly aMallatkla to tha 
tLa\. mo bvthar analyaia or data ooliactixvt u naoaaaary, but tha 
. tha adAtloi at clarttyinB iM^Aw^a or intixmmLxan. 



gaagcry >-l«airf(lclant litfoi— tion 
iha «f t~ 



: KU (fcaa not eontain au^TIciant IncoaatUn tcr IPA to fully aaaaas 
MiliiiiiiM 1 1 IwpwTt that ihould ba aiwidad In atOm to fully protact tha afwinvnant 
or tha V* Kwtimmr haa lifcK If Hfl aav naaoMbly aMallaDla altamatiMa that ara 
aitma tha ^aouia of iliaiiaK ti aaalyaad in Uia <kaft OS, ««acti oould raduce 

»yff e< tha acKlot. Itaa idantlflad additional Inftxaatlon, <Mt«, 
laaiO) itadd b> lai liffcrl In tha fUial KU. 



^St 




ID 

Doited Suta Department of the Interior 

■lUAU or LAND UANAaCUEHT 

CALVOSMU iTATi wna 



1M7 
CA-fU.lS 



Ki iiat 



OlrKtor. orfic* of tnlnMMiul Affaln (ISO) 



SukJKt: te«m of Ua Drift Eli IM fHport on Ua Ca>r4tMtM Onrotlon 
SrMKirt for tko Cantrtl UWtt rreJoct/SUU MUr Pnjoct 1» 
Callforoti 



I not baiiM UM uw ttmft KXS Mlwyraly mmhmo pountlAiiy olviifllcanc 

l^<«cts c< Om mctUn, or U» DA rwUMr tea kdancltlod r««. 
kly ■Mlloillo all 1 1ll I — UMC «« ouUld* at turn apKXna of Aiumatiwos 
mmlyma In Uw dnfx DS, irtodi MKuld te amiymd id ocrter to raAc* u» 
pouiciAlIy mit^tUMTK onrlraaankAl *-r"-*- B>ft doIlawm UMt tha IdHHifud 

ctoi, dMA. ■wlyvaa. or rtl»i— lua ar* a< oud^ a aa^iltiala tAat 
CuU piAUc cvriaw at a «a£t ataga. mt^ doaa not IMllaaa tliat tiw 
tfntt na la -**7-*** tm- tta pMpoaaa otf tto IS« an^or aacUoi S0» iwiaw, anl 
tlas aaaail ta bmaUy nalaad ma Mda aialiyila tor public a^ant la a i 
^ ravlaad dtoaft KU. (» ti» baaU oC tlw trtafalal al^^Clfiant t^acta lianlaad. 
I ter ■■'—■■t to tlH 9D> 

I *ft maaml IMO policy atf Ivooadiaaa tor CIm fcalaa a< 




[U 



IMlcd States DcfMrtinenl of the luerior 



I 



I Afa> wmjHjra KavKZ 



^ ^^ 



JNi 6W 



p : aaglaaal Mractar, MK^Oflc tagtaa, U.S. laroao af kclaatloa. 

SacraaaU, CaKforala 
Mia: lot SckraaOar 
■■ :-*t1«Ml Mractar. lailaa 1. UsnE, PortUad, Ora«on 



Mkjact: IBU: 



Crr/aif Caar<1aatad Oparatloa «graa 
■aaul SUtawt/kapart (EC as/e?) 



TM wbjact oparottMi agn 
Accortftagly, m mm oa a 



lat aaai aot Ivact tUI \tKt or prcgra 
aiti oa u> ralatad EIS. 



OHl - Utiali aad bkanftald 
M> (»»). hn nt-lS rnalar 



dfju^:^^ 01^-*-^ 



WCROFIINED 



na Flu aa< VIKIIfa Sanica tai rartawl ttia draft atnlnnKntal 
tUtanat/rapert aa tKa Caar41aatad Oparittoa Agraamt aad offan tlM 
fallaalai caaaati. 



T»a Flu aad midllfa SanXca ballant tkat taa draft oii«lro«>ent4l 
tUtdMat/raport (OtlS/EH) 1i laadawau rat«actlii« tha analysis of 
laaacti u flU ratMrnt of tM Sacravato aad Trinity «l»an aad San 
Fraaclica lay. tlto, aa lacorratt atuavtloa In daxloping tn« lb 
•ctloa altaraatin caaiat oroblHi In aMlyili that cannot ba 0»«r5:<» 
«lt»o«t ajor roanalyttt. n» aUodi and avorvchai Mad to analyi. 
t»a laaactt on fith and alldllft r*w1t> In a coni>r>atl<a nllaaU of 
»»nlcal aad bloloflcal dsan^ai dM to tha frooojad «ctlon. Tha iiu of 
anrtga snthly dau In aaaratloa itudlai of flo» and aaUr tawaratarai 
caaMt alMyt latltfactorlly daicrlba tha phyilcal comltlont that 
dataralna fli» aaten. la aach catai tha analyMt and findlnot ihoald 
ta (laMd .Ith ikattlclx aad tha baMfIt of tha dotitpt gWcn to tha fish 

22in£;i.'Lil;.2'*'4!- "^yjl. "" •" "IdUfa rasoarca< aara 
canlilaatly ra>ctad ar diacaaatad i diaiiiiiii any do<At ailstM. 

TW Praaotad Action, idilch ka> actaally baan In affact ilnc. 1975. livrovas 
natar want; In tha Dolu byt at tha ouiania of uprlrar flihary hablut. 
Iha ralaau of ara aur u ulaon aroducing straam idilc* at tlivi an 
alraady too lara hai had a Maurabia nagatin affact. The Fl.h and 
•lldllfa Sanrlci (oiltlon It that all adnno lapacti ihould ba fully 
ca^aatatad Tat tha Kis/fii ,uta. that cai^aaiatloa U m\. aaadad for 
tha C aaidlnatad Oparatloa Afraaant. 



U 



92 



[U 



Tha CooHtMtW Optntloa «) t ra^alrM tkat tlw COTtnl nHtr 

l>roJ*ct ba (ip«nta< U iMt DilU «itar willt; iUti*ir4t (0-IWS). !• 
thi OeiS/EI> thMi lUndir^l <r< cl»nct«riu<l l>r Kidl ■(tlH^laf tUtaa 
ii 'provldM owrtll rtsowm lavtl proUctlon' tit4 'protects Biqratint 
sitBM witll jnir-roiMrf ailt^mm nam i Iiiiili—IH' It It knOM Ult 
Uvrt an daflclaKlal In l>-14as •UiXarA that pracluda praUctlaa af 
OilU flUi katlut at tha ila>lr«< Inal. Slaca l«7a >tr<f^ bati Inall 
hava baa* vary poor avaa UwwflM MUr caadltloaa for rvcmltamt luv« 

Snaralljr ba«a fair u good, la fact, tJM la^cts of tha Pr«pot«4 
tloa oa ttr1pa< ban ar< aot araa 9iaatlUtl>a1jt <a>cr<b*4 la tka 
KIS/EK. l>-14as iuMir«i pr«<M taHmm ••rtiig autflo* coXUtaM 
for Juwanlla sa1««, and thora ara a* aUaiai M far ttm protactll* H 
Saa FraactKO l«y. 



Soactflc 



a. 



ftf S-1. fara. 4 - W laMaat tkat tlo 
Inpllai that tlw 'IB Actios' imi tti " 

Idtntlcal. 



tkrilar* ta Mat** u It 
•ctloa* caa^ltlaM ar* 



ficw S-;. m. t • TIN CW'I MMwl aator awflir It lUtX locomlttartly 
tnroujhxit tka Oociasot. (k paoa S-2 tka u*r1]r at tko lon lani of 
dcvalooMot 1« alvaa at 8.4 ■llTlan acro-foot. (k lofo 17, aatfor tlw 
section tltlaO 'iWiiial mur SwoKaa*. a figvra li aot tutat tat • 
refimca to Uilbit t-2 li aa^a. Eiblblt 1-2 iImm a full MnlapMat 
suppi; of •.2S4 ■inioa acr*-faat. laforwttaa oa f»f M, para. 3. 
Indlcatai tkat tba altlaau upoljr alU ba 1.2 alllloa acrv-fsat. Oa 
paga M, a jrlaU of (.1 ■llltea acro-foot It IMIcatod. latiHck at flik 
<M Klldllfa ara a (staatlal aiar of raalalaa mil— ltt«< auMly. It It 
Ivsratlaa tkat tka anvt I* claarly l«aatlfio4. 

faoa S-3. para. J - It It ililaadlat M tar tkat 'Tko l^rmmmM fairly 
protacti tka lataroits of botk proiocti <*II* aaatlai r*ipo«lkl1ltl« 
U protact tko ator rolttoo oiwli a itiit.' Tko lUtaaot ikooK bo 

rai«or4o < to r«a4 "Tka »9 It protocU tko latoroots of botk projact* 

■Alia laor«>l*| tko laval of protoctlaa affor^od tko atar rolatot 
awirn— at of tko Sacraaaato-Iao Jaa«lo Btlto.* 

Pwo S-]. Utemttlro I - SUrtlof horo, aa< tkranokaat tka ra*ort, tko 
*i Actloo ilUrMUn <t 4atcrlbo< at tko Off aaatfa* ttlu StaoOar* la 
•II bat critically Ory yaan. Villa tkit aaU boaofit tko OolU 
a«»1rni— at, aoO m hopo tkat II It icklonat. tko SocraUnr of tko 
iHtarlar la awthorlzaO only to Boot Trocy SlioiaiOi. Tko efcaapaoaor la 
1971 U BBOt [>-14«S ttMUara im a tlgalflcaat tctlaa tkat IkaaM ka«a 
boaa oaalaatoO at tkat tlao togotkor oltk aotkoHutlaa far tka oaaaa< 
fUhary cvvaaaatlOB. kocaqalzinf tko aoai to act OMictly, bBMaoar, tka 
loclllaa at aaa U aaot tko lUodar* ootll tbl<l« cmU ba coaaoctaa 
and a Hrlttoa agrvoaaat for coor4lKata4 oparotla pnparad. FItk aad 
tflldllfa rotowrcot ara tlfnlflcaotly affoctod by tkli c k iap la oporatlai 
Tka oaly oporatloa ttaOla aiallaklo for oar rralwtlaaa ara aaflclaat 



at tkay alt tka alar laoacti of tka rroaota Actla. Oyr coacora 
•baut thit k«y attaaptla at brau^t m •> wriy at Octokar 14, IM] la 
■ plaoalBi caar«lMtlw aaatlof vltk batk taraa af ■aclaaatla aaa 
Oapartaat af dbtar koaoarca tuff. 

Paga S-4. Ittt ara . - It It altlaaaiBi u itau that, la aaat tka 
proloctia cHtoHa of LAIblt A could rowira projoct oaoratloaal 
ckangat. lay ckaofo caald koa u affact. Howiar, la all catot tko 
ovorall a«>lroaaaiUI aratactla ta tka raioorca altk tko itaodards 
ticoadi tkaa af ai« of tka propotod altaratln action. ' Ua wgatt 
tkat tkll bo roorlttaa ta rood: 'To aot tko crIUrIa of Uilbit A 
Mold roalra r^iact aaratloal ikiaptt. /kiy ckaaio aold hon » 
of fat." 

>aao S-5. ara. I ~ Paak Balto aotrioa ■aaold bo*, ratkor tkaa 'cald 
bo*. rodacST ISly abaa >laad fra tka artpactia of taraa aatkly 
outriw altkt It bo ttatod that oatnoa auld ta 'tllghtly laiuaad'. 
ta lanaat tkat Ika aard 'paf ta dolotad tad ■aaraga aoatkly' udntltatad. 

Tka flal tataaca af ta aragrapk tknid ta aadad at '...«! tk ta 
Actla.* ta ta oat tallaa that tta tutaaaot at orlttoa It iiipparubla. 
Tka Igrdralaflc aad kydrallc duagai that aoyld occar la tta by at a 
raoalt of rodocod DolU atria ara itgnlflcaat. Tta laocts ttat anld 
occar U i«y ria aad alldllfa raooarca algkt ta highly tlgalflcaat. 

Paa S-d. blart tad taaarain, ara. 1 - Oparatloa la critically dry 
yaan aick pralta ylold aoald roqu Ira 'opo rat lorn la tta yaar or yoart 
laodlauly folloalai ta raplaca tta itoraa. Kai aoit roianralr 
iBfIa It talag tald for ttorago tta rtnn tala udi roiorralrt typically 
taa rary )ta flao. Tta lUtaat 'Critical man occar lati thaa 10 
arcMt of tta tia, aad aaratloa daring othar ]«ar tya> aald aot 
ilgalflcoatly tffoct itaroft ctiaat* It lacorract aad thald ta thaa god 
ta rafloct no abaa. 

Ptao S-«. Ittt port. - Tko aragropk roods: 'It ihwid ta racogaliod, 
hoavar, thot toTaa laafli dItcMtod abaa ara locti tffocts ata ay 
aot occar aatar aaratlag ataaatloa dlfforat fra chota ista la tta 
• Itaraatlat, yat ara itll) pailblo lo tta futara. tnhorat la thit 
»|i Mta'l •• tta coarttaoat by tatk tta CtP aad »P to aat ta adoptad 
tat af ttaadardp dalyiad ta prataet lalan (tad othar raioorca) aad 
ttat aaatlai tkaM itaatarta It Jadgad ara toaflclal to talaa onrall 
tka If tkaa ttoatarta ara aat at.* Thit arograpk It alilaodlag aad 
■aaappartabla. 0-14M ttaatardi ara tllghtly tattar for talaa In tta 
OalU bat tkw aacaaltott aprlar aparatlaaol ctaagn ttat aay all 
hm a adaofM l^act af gratar agaltata tka tta banaflcltl laact 
la tta OalU. ta tafgat ttat tta aragrapk ta talatad. 



>oa S-y. Wtlatia taaaraa - Tkan 
bBTwhI m B«HH W ^ sir ator 



I la a ay ttat a ' , 
ttaoratart la«<t< a talaa. 



[1 



Ita lilt aataaca af tta fint aragrapk, idild 
iro Ooalgaa ta altlgau for laoctt U tta talaa (ata attar) ratoarat, 
ind antlBf thaio aundarai la judgad ara baaaflclal U tkIt ratarca 
uiaa aot aotlng thoso lUatarai', la atra for tta Coatral lollqr a 
«olo. Tta autaal la aiaarttala aad tkald ta dolotad. 

Tta atataati la tta tacata aragrag* ttat *1ta c aiara (far atar 
tKvaratara] uliu altk ar altkaat tta h'tpa i ad Actla. ata tta Pi'tpliPd 
Actla avid tat nacaurlly ata It aiv aarM. Farthar tiadia oad 
actioa alii pra>ita addad altlatla.* tkald ta talatad alau tka 
actloa ara Idaatlflad. 

Paa S-9. Tablo 1 - ta HOfa't ttat tta ard 'raioaaklo' ta talotod 
fra tha tHIo of tta tablo. It laplla ttat otkor titoratlao 
ara unrataoblo ata ttat tta ta Coardlatia altaratin It rataaakia 
oaa tha^ tta tait itjtat ttat tta ta Actla altartatla It 'at 
profarrad bacaao It aald ban torloa odaraa affacta a tatk pr«tactt 
tta tta ailnaat.' 

p«a 22. ta lla of tath coliaaii - Tta a'ley rafarrad u It a latarta 
policy _ lilorki fra atial It autkarlad (I.O.. Tracy Jtaatardt) aad 
•hat It pitaata U ta MtbaHlad. TkIt tbald ta clarly tUtad. 

Pioa 2t, ara. 3 - Tta okjoctia of tta Fitk ota Klldllfa Jarrla't 
propolll ai to ata tta boat of a bad iltaatla. Tta flMl tataaca af 
tta paragraph UiouU ilaly itaU ttat 'Tta Fith ota aildllfo Sorvlta 
prcvoial Ml not tccatta.' * Janury 7, U«3 a ara lafaraad by a 
tay na^tlitor for tta buraoa of boclaatla ttat tta aafHIaton 
It iMpproprlaU U iBClata tta Sonrlco't prapawl. 

Pia a. ara. 2 - ta ditagra altk tta tutaaatat *la tta takla. tta 
Propoaod (ctTaTutt tta coadltloa ta idiick tta tltartatlat ara coaarad. 
Thia 11 bacaata tta Prapaud Actla aot aarly tppralala catlaatia 
of tta lUta aa.* 

Paoa 37. aitloatlw Wnajroa • Tta tta t aaa t t ttat 'Tta Agn 
o»ar4 ll raiiarcd l o»4 l »rotoc tla.' aad ttat 'Tta Udilblt A 



tta Propoaa Actla ara altlootla 



Actla ara altloot' 
ata ara alalaadfag. 



Ua affoctad oanronnatt. 



lat for tta prajatt.* caaaat 
ta tatftat ttat tk« ta talatad. 

clKa lay aat ta iKladad a a« a« 



Paa 39 . _ 
Alvar taila li 



It ihald ta aatta ttat art ar tta THaiqp 



OMi iattlta ■ 

IdaraJ at wrt af tta raglaaol tattlag. 



Paa i1. nat to lilt ararata - TkIt aragropk tkald ta corractta M 
raid 'Doctila 1US prinlda a tllghtly tattar lanl of protoctia for 
lalaa la tta Dolta ttan occarrta idia tta CIP at opontta aadar Traqp 
Stantardi.' ta arltta, tM tataaca laKa ttat thara <mT% a ymr-fm 
ainlaa fla proolttia for tta SacraaaU llnr at Ho Vltta. 



m 



Paa 73. Enrlroaatal Con aa aancw. Ulrora aad kataryolri 
Tta tocota taataaa theald ta ctaagta ta raod 



Paa S7-M - Tka frapaata Actla ad ta Actla altaniatloM ara datcrlkta 
ralttia ta a aaa-ailttaat kaulla. la ar Tia tta M Actla altanatia 
tkald ta tta taalla. 

Paa <4, Affatad bwlraaaat. Catral Yallar Prejoct Sonrico Aral - Tta CTP 
coiBltatat ttatta u 7.32 alllla acra-fat doa at agra altk Tablo I, aa 
W, idilcb tkaa a iialMial af 7,132,121 acra-fat. ThIa diacrapaacy akald 
ta aipltlaad. 

,, -■ firat para . - 
Tta dirroronca atald aria 
la cHtlcal yaan aad tta yaarlt) Jaadlataly falloalng cHtlcal yan.' 

Paa g - It aald ta af lafaraatloaal nia ta Matify tta paaor aaata of 
borvico tatckoria aad ra f agai ta tkIt tactla. ApproprItU aoralag cm ta 
wtratad fra ar Flak aad Vlldllfa Cardlatla Act laport a tta COA. 

Plot 93. Aduarao Ciwli u ia a nul tffoctt Ttat Cannot ta A»olda - It ahald ta 
ra c ognlita at a otaroldafcia offoct ttat ilalflcant ad»arao lapacti to awr 
fWliitara la tta apar Sacraaatt ata THalty >1<tn aailo occur alth tha 
Prapatad Actla. llkaala. a radactla la tta agitata ami fraqaacy of a'b 
Oolta atria to Sa Fraacltca tay It uaaaldoblot tta caaagaaat af tkIt 
ctanga t» flak tta alldllfi kaa aat baa tataralnta. 

Paga 93. lfTa»arllb1o ata Irratrlwablo Coaltaaatt of koioorcw - It ihoald 
ta atatta ttat tta Propata Actla aay Invola a Irrarartlbia or Irratrlaabia 
caaltaaat af raiarcai If tta aintar-ran rte» of chlaooA ulala la atlrpatta. 
Eva If at oatlratta. tta laaa In alntor-raa ulaaa ttat accar la a glaa 
ywr ay tat ta raplacta la aaktaaoat j^An. 

Paa n ata 97. dkalla Arriaaaaan t i ata Parctaa of cyP tatar by tta SMP - 
UMar tkaa baa tactlat It tkald ta lUtad that tta Incraantal laactt of 
Back Ktlaa aald (I) laraa tta loit of flih and flih food orqantia at 
aipart facllltla. (2) iKraa chaal valocltla, alraaOy too high. In car^ 
Ula OalU ekaaalt, (3) oiacortau tta probla of rorarao fla In coruin 
OalU ekaaalt, (4) fartkar radaca OalU atfia to Sat Frtnclico by, (S) 
Incraa ctaaal tcaar ata tilt dapaltla. ata (A) mnm aur-laval dr«i- 
doa la tta OalU aar aipart facllltla. 

Paa 97. Miyfl of tta wpratoria a ka tator Sarrlca Contracta, ara. I - 
Tta SocraUrlal aaratarlia aacowaaaat aora ttan la ocknoalodgcd In tta KIS/ 
En. ta lapaftaat prala af tta aontala la ttat lb long-ura c<^IOOMtt 
alii ta aata by tta SacraUry tar ulo or Inuria or tnuralttont aUr until 
tta Ilia 1^ Initraa fla aaata la tta araai of origin or iffactad atari tat 
baa rauWM tta atl1 tta atar natat far algraUry blrdt m Cantral Vallay 
tatloMi Ulldllfa AafutM taa baa at.' Thli ahald ta clarly tuta la 
thIa tactla at all at In ralawt tactloai of tta auaary. taftigo noodi 
maat U S3S.000 ara-faat aaaally tta thaa ata latraa fla naadt ara 
aora rally daicrlbad la mr Flu ata dlldllfo CoordlMtla Act tapart a tta 
CM. 



93 



E 



DCPARTMENT Of FlSH AND GAM£ 



Hr . Da*« Houston 

K*9ionAl Dlractor 

U. t. ftur«Au of McI«aKtion 

2B00 Cott49« Hky 

•AcrAMDto, CI 9Sai4 




C^^r%^^ 



t«v*r*l ■ontbs *«o **• dlscujivd tlM CoerdlfMtad Operations 
AiTTvcBont. JU I lAdlcAt*<l. Fltb and C*a« supports tte «9r***«nC 
but b«lle*as It's ssssntlsl tb«t tM A*sl with •s-rsr*! fish And 
vildllfs Issuss during tba wstsr BKrltstlng procass. 

lines tiks Aurasu and tha Oapartaant of Malar Masourcaa bava 
startad na^otlatlons on aarkatlnf vatar aad iMva Inltlatad tbo 
anvirorMsntal lopact procass. ««■ ataould start daallnf with tha 
fish and vlldllfa lasuaa now. Hopafully that vlll produca an 
accord by tba tlaa that you ara raady to aarkat tha mtar. X 
su>79cit that a«ch of ua appoint a stAff paraon to ba^in 
negotiations. IHs na^otlators' flrat tAak ahould b« to foraiXata 
tha lasuas to ba consldarad and prapara a tlaa achadula for 
na9ot iatlona. January 1. 19t4 would aasa to ba a raaaanai>l« 
daadllnc lor coaplatln^ that atap. Ma ahould Invito tha Fish 
and Nildlifs larvlca and tha Oapartaant of Matar laaourcaa to 
partlclpata. 

I look forward to an aarly raaponaa to thia proposAl. 

Ilncaraly, 

rat 
Jack C. Pvnall 
Dlrpctor 

cci 0. Kannadyt^ 
B. Hyahak 

AC C .yt— -i— 

/ \ . )j "' ; 



//T?^ 



Mcmarondum 

^ ■ 1. tTojaet* >•— ~«l-TTTr 



^ 



*«o ft. 



^33/ 



JKmatMZ •, ms 



D«f«rt— Dt of Mtar tmrnprnremt 
I2S1 ( lUMt, toea 0-4 
McTuute, ex tSll4 



C«itx«l T<U«T rTe]*ct/«ut* Mtu »ro).et, «CI IJOdSOl 

it^ of tb« oaputaut of ri«h ud euo lUTC tnlmmA tho ll$/ll». 

Co««itii h*™ bMn rto»«r«l ud uo «oXtla« for roYlov tad •im.toz. 

of BOUT iMoarcM u tfeoU ami Uttox of (optoabu il. mT^ 






C. Plotchoc 
Do^ty Oiroetor 



IS|i«i)D 

"' N0VO8198S (^ 

•uuatsaavbmo 



■*■ <» c **^»i* — I 



OC^AKTMCKT Of RSH AND GAME 
(«1«) 44S-3531 



Nr . Dava Kannady 
Dapartaant of Matar taaourcaa 
Hl« llnth atraat 
•acr^nto. CA «SI14 

Hr . X>*wm Bowston i 



//T)'-^ 



ar IS. 19I5 



Ouarantaad ralaaaaa (fob Trinity Laka via Mhiakaytown Laka 
Into tha ftacraaanto Rlvar during tha fall vhan taaoaratura 
problasa In tha SacrSMonto Rlvar balow Kaawlck ara BOat 
pravalant. 

Ouarantaad ralaaaaa froa Ihaata Daa to act aa dilution flowa 
whan watar bahlnd Spring Craak Dlvaralon Daa la ralaaaad or 
aplllad during fall and wlntar atoras. Such dilution flows 
ara critical to avoid concantratlona of haavy aatala In tha 
Kocraaanto Rlvar balow laawick Daa that ara lathal to aalaon 
aoga and fry. 



O.B. Suraau of Racla 
2S00 Cottaga Nay 
Sacraaanto, CA tSia 



Thank you for tha opportunity to oosBMnt oa tha Draft Bwvlroaasntal 
lapact Stataaant/aaport on tha Coordlnatad Oparattonf Agraaaant (COA) 
for tha Caatral Vallay Rrojact (CVF) and Stata Vatar Prolact. 

Aa a truataa agancy ovar natural raaourcaa In tha Stata ot 
California, tha Dapartaant of Plah Gaaa (DPC) auat coaply vlth both 
tha California Bnvtrofasantal Quality Act (CtOAt and Batlonal 
Bavlroflawntal Rol ley Act (SIPA) and our ravlaw of this ilarmm^X aaiat 
aatlafy both atatutaa. 

■a hava ravlawad tha Draft BIS/BIS and hava dlacuaaad It with ataff 
of both load agancias. «a find It Incoaplata In Ita traataant of 
iapacta to flah and vlldllfa raaourcaa aaaoclatad with tha OOA 
Itaalt. and aa hava eoncama vlth tha way It addraaaaa tha CW aa It 
ailata today, and pctantlal aarkatlng of additional watar. 

Ragarding pctantlal Iapacta of tha Agraaaant ttaalf, tha raport 
baglna to addraaa tha problaas, but Is Incosolata. ^w raport 
indlcataa that watar uaad to halp flah In tha Dalta will ba at tha 
aipanaa of flah uoatraaa. In a vorat-casa analyala, 90 parcant of 
Chinook aalaon will ba loat In thalr apawnlng bada whlla downatraaa 
algrants In tha Dalta ara protactad. Thla no-wln altuation la not 
accaptabla froa a raaourca atandpoint. In addltlonf tha Ruraau'a 
oparatlonal atudlaa (ualng aonthly taaparaturaa . ate.) daacrlbad In 
tha raport ara Inaufflclant to Idantlfy all Iapacta. TtM aola 
altlgatlon proooaad for tha Agraaaant (paga 37) Is tha Bihlblt A 
atandards of tha prafarrad altarnatlva. Rowhara In thla ashlblt la 
alt igat ion propoaad for upatraaa Iapacta In tha varying acanar los. 
Bpaclflc altlgatlon aaaauraa for thaaa iapacta ahould ba oontalnad la 
tha dociMant and would Includa, but not ba llaltad toi 



Ouarantaad ralaaa 
to laprova tha an 



la Into tha Trinity Rlvar balow Lawlaton Dan 
tdroaoua flahary aa propoaad by tha Trinity 
*orca. 



Ouarantaad conatant low-flow ragiaaa (l.a. alnlalsa flow 
fluctuations) balow laawlck Daa batwaan Octobar 1 and Harch 1 
of aach yaar to ainialia loas of aalaon agga and fry daa to 
dawatarlng of radds. 

/ - ^— , , ^ a ' -^ *C i;. C' 



9. «o naw watar aupplv eontracta oooaiMaatad until our Sacraaanto 
Rlvar inatraaa flow atudy la coaplatad and an adaquata flow 
•ohadula guarantaad by tha Suraau. 

ft. Ouarantaad hlghar ainlaia pool In Shasta Laka to halo alnlalte 
taaparatura problaaa In tha fall in tha Sacraaanto Rlvar balow 
laawlck Daa. 

Modifying CVF oparatlon and aattlng aalda a portion of cvp yiaic 
aay ba naoaaaary to laplaaant tha abova. 

In addition to thaaa altlgatlon aaaauraa, tha doctaMnt ahould 
inoluda datailad analyaas of how dallvary achadulaa raaulting froa 
tha COA aay incraaaa tha daa and by landownara for additional bank 
protaotlon projacta aloag tha Sacraaanto Rlvar batwaan Raddlng and 
Chleo Landing. 

Tha eoAolualon that about oaa ailllon acra-faat par yaar of 
'uneoaalttad* watar aupply will aalat at "full davalofwant* 
•POaara to ba baa*d on tha aaauaotlon that Inatraaa flowa In tha 
Trinity and Aaarlcan rlvara vUl ba raducad at that tlaa. Tha 
flowa asaw«d for tha 'full davalopaant' atudlaa hava baan 
d sa ri n atratad to ba Inadaquata to aalntaln flah. wUdllfa. and 
raoraatlonal raaourcaa of thoaa rlvars. 

Tha dootSMnt alao ahould addrass potantlal Iapacta of tha 
hgraaaant on tha Ban Joa«uln Rlvar Byataa and propoaa altlgatlon 
aaaauraa. Thaaa ahould Includa aaaauraa to protact tha fall 
Blgratlon of adult aalaon froa tha Dalta into tha San Joaquin 
trlbutarlaa to apawn and tha aprlng and fall chlnook out-algrants. 

Tha docuaant polnta out Ipaga S-7) "tha propoaad agraaaant could 
ba eonaldarad a link In a chain of avants that could laad to othar 
acttona that oould hava algnlflcant anvlrofwantal laoacts.' Wa 
agraa. Tha chain of avanta bagan with tha authorisation and 






94 



[E 



C, '«W^9 - TiMU i ^pKlflc mi—lUlllKl kgr Uw rilk mt 
S«r>1ce' wtrt not utelturf by us it i ii i— wiitlww. TIwm ar* 
fw of Um miv tdMi/flMdt th«t mn d1tcyis«4 1* tM Flth tM 
Stnrica Inpyt of DKoter l«>] to tko KlS/Clt. Frvparan of tM 
otfwr than tM Mth mwI WUdllft Santlca 1ttt«d t>MS4 fiw IdMS 

lopod tlH rtspoAMt. PrviMtlni an Incvplata lift of owvli u nwiital 
Mrlousljr altlaadi Om roadar at to tM poiltloM and r>i lawaiiilatlOM 

Ilk and Ulldllft Sanlca. Ua ta^tnt tuat tlo laad-la tmtawa ba 
to raad *Vm of Om coKwi of tka Fit* aM Ulldllfa Sanlca ar* 
■ :■ Slallarl; rvtitit tka toadlaft al Kaman Ho. I', "CoKon Do. 



^ppandta 
Wlldtlf. 
sit»lj a 
• lldHfa 
I)£[5/EI« 
and dm 
coftctmt 
of tin F 
r««Drdad 
» foU< 
Z\ au 

On pi9« t, 7, and S Ua f«inaii ta aar CMcani M. 4. tMai* l«>|tli]r. Ii 
tncorr«ct and Inadaqyau. Ha baltaa* tJiat ma »i u > wi ad Action "Mowld' ratlwr 
than "Mif* tl^niricantl/ la»act riib rtiMTxn. FartMr, aa baltaoa tkat Om 
ifltpacts Moy)d occur In critical dry jvara and In tM yaar{t) followlnl. TM 
discutilon on tM fraqaancy af tl^lflcaat la^acti It Incorract bacaaia. In 
our opinion, tM Incorract M Actlaa altamatlva aat utad for aaalyalt. TM 
irq<aant on ptfas 7 and ■ tMt flit alii find Italatad tMnal rafafal It m- 
sgpportabla. Oaarall, IM t4>llM raiaaaaa U Caacara M. 4 It In aaad af 
najor r*-Brltlnf. 

SiM»nr Ca—nt» 

It Is unfortunau tMt aftar aar afaaclas hava wrMd aa clotaly tMt tMrv 
ira itin suck diffarancat la tM aMiytIt af lawcts aa fltb aad alldllfa 
rrsourcat. Our aajor problaa alU tM MIS/El* itaaa froa idiat m Milan 
•Ji ba Incorract atuavtlens laadlna ta Incorract oparatio* ttudlat. Ha ha- 
Kara tMt ta M adawata tM a«»li u —iiUI aMiysIt att W Mtad oa tM 
propar M Action alUrMtlva Infaraatlaa. M alii assist la idutavar aajr 
11 naadad ta aaka tM«a corractlaat sMald yaa a« raqaait. 



AU (W), ms. tartlaad, 01. 
NO (Ml), nc, Portlaad, O. 
An (Ft). FW. Portland, 01. 
FVS/EC, aatblnitaa, D.C. 
FUS/ES, (Fad rnj). Uasblaftt 
UrI Vlnklar, CA Oaat. Uatar 
SacrtBMta. U. 





*' M.. Coanal fallar frajact/ltata lalal rnjact, Calilarala. 
DO-U/il 

. _.,k »fc. - 1% itu aMiiia-' - tnm y««x Dlractax, OdClca 

of fciiliaaaaaial AlfaUa, w hwa tailnMd cm wajaca ^"' ■" 

lollaalM I MT I. 

T^ TrUlc. Ua«s balaa LaalaCM Ma, aad CM avrlcaa tlrar. Mlaa aiabu 

T^Vly^^ZriL*^ rl~ ...M ... .".ctad b, tba '"^^'^'^'^L^ 

■ „d aai -— r- la fl«a rafUaa foa tMaa rt»ara caOi bar. an lw<t 

« th. Talaaa atacaccad by tka laclaaal mA Uaca iyat— danHnntloai .faly 

^T^ tM Dt/m abaald a,«^K»UT UantU, cM raintal/itac^WU aad 
1* Uma tyata. l«alaaaaat aad tM Mrix«-aat«l C^aaaaaacaa aactla. 



Icanlf Uaaia tyaei 
abaald laJIrata A 
eaaalaCMt alck tM ttata/ t ada a al Acta. 



CM piaaiaal aad altaiaatlaaa 1 






yo 



JfV^^jjMJl^^^^iVi*-* — 



(7U) 



m 






;il'i:".~jil«15~!»I») 5J1-U7« 



|...At. IT. TO! 



opcraclas vlll wc cc^lUt with tlmmi eounl m mt^mt 
pnmttmt vltkla a«r JwIaUccLm. ThMfe yM C«r eMrtlMUag 



^Jtr. 






UALtn nr 

ggal. PInMlna Mrtataa 



cu^ 



:^.e^^lL 



95 



-1- 

conatructloA of th« CW, coatlMMS to4«r« and has no cl««rlr 
leflnvd •ndpolnt. unlass a conclualT* ttJMtabla and Bachod for 
how ovarall CW lapacta and aarkatlng of watar lapacta vlll ba 
dddraaaad la provldad, wa ballava that taction 191(n of CBOA, 
'Whara an Individual projact la a nacaaaary prac*dant for action 
on a largar prolact or coaalta tha Laad Agancy to a larqor 
prolact, with algnlflcant anvlroi^Mntak affact, an llll auat 
addraaa Itaalt to tha acopa of tha laroar pro]*et* ahould ba 
followad. 

'"^ur DaoartAant ballavaa thara la a nm^a to addraaa tho ctMHlatlv* 
inpacta In addition to ttta onaa directly cau«a4 by th* COA. HIM 
isactlon l^nt.])) r*qulraa thla aa wall. TVia COA ahowld ba out 
Into tha parapactlva of tha laroar acopa of tha CVT or asplanatloA 
Dfovldad aa to why not and Kow and wteara tha load aoancloa «lll 
•ddraaa thaa* bro«4ar laauaa. 

Tharafora. If tha oam/Hfl la to raflact potaatlal osMlatlv* 
lapacta bayond tha laoacta aolaly cau**d by tha COA. It ahould 
•ddraaa both Incoaolata altlqatlon for lapacta froa tha CW aa It 
axlata today aa wall aa potaatlal lapacta froa Incraaaad aarkattng 
of additional watar. Oua to watar aachangaa In tha Oalta, thoaa 
lapacta aay occur anywftora wlthtn tha tacraNanto, tan Joaquin, and 
Trinity Rlwar ayataaa. h tmm aaaaalaa would bai chano*> l" 
raaarvolr lawala and taaparatyra. altaratlona of rlvar flow and 
taaparatur*. tha Introduction of toilc aatarlala Into watarvaya, 
and tha reduction of avallabla watar to watarfowl and otbar 
wildllfa. If tha laad aganctaa ballava that thara cannot ba full 
■Itlgatlon, tha raaaona for thla abould ba aiplatnad aad d»alt 
with. 

wa nota that tha fturaau In a«waral doo^anta haa atatad that flah 
and wlldllfa goala na«d to ba daalt with coaprahanatvaly for tha 
anttra araa affactad by tha CW (JUi AporalaaL of Total Watar 
Nanagaaant In tha Cantral Tallay ftaain, California. It7]| aorklno 
Docx»ant 13, l«7ti CVPma Mawalattar. Aorll Ittlt I. IIHM ttoport 
B-7, 19I4>. 

At thla tlaa wa do not Intond to Hat all unaat altlgatloa 
aaaauraa na»dad for tha COA for the CW aa It ailata today, or for 
tha aarkatlng of additional watar. Thla lob ahould ba coaplatad 
by tha laad aganclaa raapo«albla for tha tllt/BIS oa tha COA. 
nowavar, wa ballawa thla taak could ba facllttatad by tha 
foraatlon of a atata/fa4aral Intaragancy taak toroa coi^rlaod of 
tha laad aganclaa and tha fadaral and atata flah and wlldllfa 
aganclaa. Ma hava prawloualy auog««tad tba foraatlon of thla task 
torca. 

Tha taak forca would, In affact, aaalat with tba ooaalatloa of tba 
oeiR/sis or othor approprlata doctManta to anaura all na adad 
laauaa ara addraaaod. Ma would work aipadltloualy on aueh a taak 



(oroa to ooaplata this analyala bafora tha tlaa tha Buraau la 
raady to aarkat aAdltloaal watar and hopafully bafora tha COA la 
algaad. 

Aa wa ha«« atatad pravtoualy. provldad that tha lift/BIfl fully 
»ddr«aaaa our coneoma and/or provldoa a eo^ltaant that would 
laad to a aatlafactory raaolutlon of all flah and wlldllfa 
probl^M ralatad to tha oparatton of tha ovarall CVP, DPG aupporta 
tha algnlng of tha COA. Tha COA Itaalf la allant on laauaa 
outalda tha Oalta, but to ba placad tn tha propar oarsDactlva, 
doclaloA aakara aawd Inforaatlon on all tha laauaa which ara 
rolatad and thaaa ahould ba addr«aaod or achodulad to ba proparly 
addraaaad. 

■a ara aa^ar to abara tha burtfan of thla task. 

Slncaraly. 



AJack C. »arnall 
' D tractor 



m. 



wtM uaOM laata imwiMm 



Octotxr 31. i9es 



OepirtBMt of Uaur Rttourc«t 
)2S1 S. StrMt,' llooa l>-4 
iKrtmtntc. CA 9Ult 



Drift EIS/Em for Uw hxpoiM CoordlMUd Opwitlon tqrtmmn for Ua 
Fe<)<ril Otitral ••II.; frojKt tiX Ua Cllfomt. SUU WUr rraJ«t 
SCH« 85092303 



Dm lutlx ABrlca. l»rlU9. CoBiiilai tpprtcKUi tk* o w m Hi H. t» 
eicmi lU conum tni c iM iii U la Om aHlroanUl mlai ,r«c*H. 
*s you aajr kin., tk. UbIiiIo. Ii aaMalai t. ,r. i «r»« aiK .rvuct 
placM of >p«ial rtllgloM or altanl tlvlfluaca C* ktln »»i Iim 
puniunt ta SkcIo. toil at u« .f Oa Pl*1lc 



Tha CoiBlaalw taa tk. fartlMr 



. ' aialtcln 

In caHUry aM turlal oratKtlaa MnMkt t» SKttoa StHl.Hlk) «f 



Ikllltr (f aialtcln htlM 



fUlIc anaamt Co4a. SkoaU I 



■IM Of latin MvlcM er1(t« 



Ka iKumtMnt Airing t*. r«J«ct, la rtqat l t tkat Ua Cawitr Caroar't 
Offica ka coatKU< wnwat f tk* ii ut ifci M Ht firtk Ik Sactloi nw.i 
of tka Haaltk MM SafaDr C<«a. 

la aritr U kltlfato HtMtlal l*actl t. Ultfwmla IMlM akoitnl 
bMrlali aia otkar CklUral n%mrcn aurlaf tk. cwn. of tkli .mjkct. 
M r«)unt tkat jrw ckkaalt irllk la^laa l*<l>l«ala akt/or pu^l Ik 
tk. projoct ar«a. 

Pla«M <o aot kMluta u ckktkct tka Caalulak ftr aagp tialitMci raltttx 

to tk. akva. 




tin Aatlttkkt 



f 



96 



i*fi Of c*t»Qaa> oppK i at M ( 



[U 



Oma Of PIANNING AND MSCACCM 



"ovattar a, 19P' 

url HIntUr 

Ileixrtant or MUr Disoymi 
32S1 S StrMt. Una D-4 
S<criM«u, CA. »81i 



il <■ 



ail)J«otl Or.ft EIS/EH for tlw prO|m« CoM^lMUd Itpontlon tant llt for 
t(i« Fxliral Cmtral «i1Uy fnixX mi tlM Callfenila SUU MaUr 
Projact. SOM 8509230] 

Ctaw Nr. yinklar: 

S:ii^?1!,S^TTfT "*^«««' »• •««~ ■->" *»" fcrtrm-ital bdM 
Sei>o« (Km) to oalMtad ataU aamolM for ra*l«. Sm ranan parlod U 
cloMd ardOia ■ a n ill of Oi. lnJl»l««l mm-aiim} U(ara) anoloMd. 
^ao. on tba anoloMd HMlo* of Oavlatlai. Ila CUvlMnaa tea olsokad 

!!l'!l*Sr;^ '* ~'— - **^- "— ""^ *• *«" rf C<^UtK« 0, 
Mum cnat rov iniiil ladaaa U oavlau. If tiia paola^ la not U 
S!*'' I'l**^ notify tba 3t*t* Claarii^maa I— llalilj tour aUlt auit 
Stat. QXmm^amm it^m- abculd ba ■»> ao tiat •• au nvu proIptljN 

PlMaa ncca Hat laoanc la(Ulatlon raqutraa KM a ■— r— -1- a^j or 
r^LS?"!.;*'""' •S^'*<if~^ mjtmaaam csaMa on a praj«>t «ldi 
i^J^SJ; «^ •« " ««» ••noya aipartla. or lOlA raUt. to aotlrttla* 
*l*^aiat amr am oarrr out or aivroa*. (IS 25*3. Ch. 1B». 3uta. 

■»»aa I ma trt fooanlad for rxr usa In prap*rli« joir fUal HX. If 
ycu nea d aora ijifonatloi or olarlfloatlxa, ■■ ai^aial jou oottoot tta 
°<^antlnf aaanojr at your aarUaat oananUoao. 

naaaa oontMt N«Br *»o™ at «H/«*i-0«13 If |ai laa* av qiaatlaa 
Slmanlj, 



. ia:!.i'i::i!.i'i.it^')n7aa-;L-a,«;ii'i;.fgr,!:iJ.- 




Jam B. (feBilan >^ 

Chief OafiutT Dirvetor^ 
Orrtoa of PUmliv nd TIiimi iti 



Memorandum 



m 



' Karl Ulahl«r 
DspartaaDt of Hater ■••ouroaa 
3251 3 StrMt, Booa I>-4 
Saoraaento, CA 958l6 



itr 7, l« 




•TAT1 WATUI WOUWCM 



cownrrs <m tu jolt i9fls Di&rr uTiionwrru. xwact STiTUCvr 
AMD BiTiiioaHurrAL ZHPiCT iBPorr (diaft tia/izi) m to pioposbd 

COOROIIiTID OPBIATXOI AOaUHlVT (COA) BITtfBU TBI PBDflAL CBVTIAL 
TAtXil PBOJBCT (CfP) UD CALXPOMIA STATB VATU PBOJICT (SVP) 

A oop7 of your draft BIS/IXB that M* avnt to tba Btata Matar 
Raaouroaa Cootrol Board (Stata Board) haa baaa rafarrad to aa for 
ravloH aad oo^MDt. Hy gaaaral ooaaaata ara provided below. 
More detailed oo^aote ara attaobed. 

In ganaral, i*e ooaalder tbat tba draft IIS/BIB falrlf daaorlbaa a 
sound •nvlronaeotal baala for eeleottad tba OOA over poteetlal 
alteroatlvea. Bowevar, tra beliava tbe proposed COA ooBtalaa 
oertalo ant Irooaeatal flaaa tbat are aot adequately deaorlbad ta 
tba draft BIS/BIB. 

Hoat notably, tba draft B13/iZB aaaarta that tba oeatral purpoaa 
of tba COA la ta a^** lo-baaia aaada, laoludiag Delta vatar 
quality proteotloa, priority over CTT and 3VP eaporta tr«m the 
Delta. Tbla la aot entirely eorraet beoauaai 

t. The COA ooatalaa prorlaloaa for taralaatlaf obllfatloaa to 
aaat tba Bzblblt A Delta ataadarda If tba StfP aad CTP fall to 
enter lata aa« eoatraata to looraaaa eiporta froa tbe Delta 
or fall to obtala aetf vater rtgbta ta aoabla tbeae aea eiport 
ooDtraota. Tbua. tbe teraloatloa provlaloaa of tbe propoeed 
aotloB appaar to glva aav axporta priority over Delta water 
quality proteetloa. 

2. Contrary to atataaaata aada ta tba draft BIS/BIB, aaetlat tbe 
Bxblblt A Delta Staadarda. wblab ware aitraotad froa the 
State Board's Deoisloa 1489, doaa aot assure tbat all 
upstreaa la-baala uaaa la tbe Saoraaento River and Saa 
Joaquin River baala ara protaated froa CTP aad StfP 
oparatlooa. 







s 



3. Tka ,roraaM aottOB doM aot aaaura prot.otlaa of Is-baalo 
UMa 4oinatr«u of th. D.lt« In 3utaon Marak antf Saa 
frnnalaao lay. 

ConM^iMatly, va Mlm. tba aoTlronaantal analyala la tba Draft 
■IS/III abouK b« BOdlflM to taka Into aooouot tba flan In tba 
profoaatf aotloa doaorlb*d abova. Otbar obaa«aa abould b« nada In 
aoaordaaaa ultb our attaobad datallad oo^nta. 



Thaak yoa for tba opportinilty to oo^ant on your draft lla/III. 
If you kaya any quaatloaa, plaaaa oall aa at (916) 32«-ST3a or 
aall Mr. Daald larlafar, lay-DalU Prograa Manaaar, at 
(9 It) 322-9tT0. 



Bob Sobroadar (ii/attaobaaot) 
O.S. Buraau of laolaaatlon 



97 



m 



itt«ob*aBt 



OBTAILID C0IMUiT3 01 TUB JOLI 1905 MATT m t lOVIS VT&L IIVACT 
3TATBKBin AMD BHVIROHWITiL IWiCT RKPOIT (DIATT IIS/BII) 01 TVI 
PROPOSIO COOIDIRiTICW OrSRiTIO* iOUIMtR < COi ) UTMII VU 
FEDER&i. CZrriii, TUXXT PROJICT (Crr) AID CALIPOUIA MATl MATBI 
PflOJICT (3tfP) 

1. Pm« ^3* Uaft Coluaai 

Th* first full pArafi-apb atAtta la tk* iaat •••iaaoa that 
th« COi profldas tbat If tba p&rtlaa fall to raaob acraaaant 
30 tba purobaa* aa4 ooavafaaoa aoatraet oallad for lo COA 
Artlola 10(b). tba COA aay ba taralaatad by altbar party 
andar Artlola 1«(b). Tbla dlraotly ooafllota wltb 
aaaartlooa aada oa paga 3-2, laft ooluaa* third parafrapft 
tbat tba purpoaa of tba COA la to (Iva Oalta tiatar quality 
protaotloD priority ovar aiporta froa tba Dalta. Tba final 
BIS/BII aboald ap«oirioaXly addraaa tbla laooaalataaoy. 

If tba COA aaa ba tarvlaatad upoa fallur* to aiaouta aaa 
cootraota to Ineraaaa aiporta fro« tba Dalta, tbaa tba COA 
«ay actually ba glvloi priority to sav aiporta ovar Dalta 
watar quality. Tbarafora, tba floal ilS/BZl ahould addraaa 
tba poealblllty tbat tba propoaad aotloa (COA) aay aot b« 
battar than tba lo Aotloa altaraatlvaa. 

2. Paga S-9. TabU S-li 

Tba flrat footaota appaara to ladtoata that Boaa of tte 
dlBadvaatagaa llatad for tba TarLoua altaraatl*aa ara 
alcDlfloaat advaraa lapaota baaad od CBQl orltarla. Hhlla 
tbla aay ba trua ralatlva to tba propoaad aotloa, It 
oartaloly la not trua ralatlva to tba othar altaraatlvaa, 
aapMlally lo Aotloa. Caa* A. Tba flaal BIS/BII ahould 
corr«ot tbla arror. 

3. PM« t* ilfbt ColMMl 

Tba paragraph dlaouaalog (X)A Artlola 4 llata tha varloua 
condltloaa uadar uhiob tba COA say ba tarvlaatad. Our 
coooarn ralatlva to tba ooodltloa wbara tba partlaa fail t« 
raaoh oaa ooatraota for looraaaad aiporta baa alraady baaa 
aipraaaad lo Itaa 1 abova. iootbar ooodltloo |l*aD rafara 
to COA Artlola 10(b)(9), atilob atataa that If altbar party 
falls to obtain sufflalaot aaw watar right parvlta or 
asaodaaota to aslatlog paralta tbat will anabla aiaoutloa of 
Daw Qootraata to laoraasa Dalta aiporta, tbla oao ba grounds 
for tsraloatlog tba COi. igalo, wa a*a tbla aa anotbar flaw 
IQ tba COA that uodaralaaa atataa aata aada la tba draft 
BIS/BIB tbat tba prlaary purpoaa of tba COA Is to giva Dalta 
watar quality protaotloa priority ovar aiporta. It is 



s 



looally affaotad by CfP and 3W? oparatlooa. Tbarafora, tha 
final BIS/BII ahould not olala In any way tbat tha COA 
protacta all In-baaln usara upatraaa of tba Dalta. lor 
sbould It olala tbat all baoaflolal uaaa tbat aay bava 
priority ovar tha projaota, looludlag thoaa la Sulaua Harah 
and Saa Praaolsoo Bay, ara satlsfiad. 

5. Paga 12, Bight Coluaai 

Tba flrat paragraph aiplaloa la tba Iaat aaatanoa that uadar 
COA Artlola 10(b). tha SVP will puap by iprll 30 of tba 
following yaar up to 199.000 aora-faat of CTP watar forsgoaa 
dua to CTP aiport raatrlotloaa tba pravioua Hay and Juaa. 
Tbla provlaloo la baaad on Ordar Condition 3 of Daolaloa 
ltS9. Bowavar, aa aiplalaad to tha partlaa la a lattar froa 
tba Board datad iprll 12, 198*. suob aakaup wbaoling is 
allowad only tbrougb Harob 31 of tba following yaar, not 
Cbrougb April 30. ipproprlata oorraotloos should ba aada la 
botb tba flaal BIS/BIB and tba COA. 

6. Paga 25, Laft Coluaai 

la tha third paragraph, obaaga tha data tha Board aipaota to 
ooaplats tba ravlaad staadards froa 1908 to 1989. 

7. Paga A, Laft Coluaoi 

Tba arrata abaat glvan wltb tba draft BIS/lIB proparly 
oorraota tha alaatataa«at lo tba flrat paragraph tbat 
Daolaloa IAS9 did not looluda ataodarda to protaot offahora 
H A I watar quality for Contra Coata County. Bowavar, thia 
oorraotlon ahould ba oarriad ovar into tha aait two 
paragmpha aa followai 

a. tha flrat aaataaoa of tba aaooad paragraph aboald 
looluda tba folloaiag addltiooa (uDdarllhad)i 

'Oodar Daolaloa 1*89, ohlorlda ooataat of tba watar at 
•Itbar look Slough or iotlooh Watar Mgrfca lataka o^ th^ 
San Joaquin II Tar la raqulrad to ba 190 ppa or laaa for 
a alolaua of 159 daya par yaar and look Slougfa aay not 
aioaad 250 ppa." 

b. Tba first aaatanoa of tba third paragraph ahould ba 
abangad as followai 

'ntM4€t OWI ^HtUn^i Bp BMJ^fO 79M. ^aabla watar 
*<it%i^4$ U Bd la avallabla for dlraot divaraioa la tha 
iotloob-Plttaburg araa for varying aaouota of tlaa . 
dapaading oa pravalliag bydrologyT* 



'•J 



m 



J' 






aoooalvabla tbat tba partlaa aay not ba aOla to obtain all 
tba watar rlgbt parvlta or parvlt ohangaa thay want to oovar 
oaw aiport oontraots, slaply baoausa thara aay not ba 
sufriolaot watar avallabla for appropriation. Tat this 
taralaatiOB provlaloo In tba COA would allow tha partlaa to 
abandon obllgatloaa to altlgata tbalr affaots on tha Dalta 
uodar Qurrant aiporta If watar rights for oaw aiporta whlob 
algbt daprlva ailatlag banaftolal uaas ara not approvad. 
Tbarafora. wa ballava tba taralnatlon olauaa of COA Artlola 
10(h)(9) oould ran4ar tba COA to ba ao battar aovlroft- 
aaotally than tba lo Aotloo altarnatlvaa. Tbla poaaibllity 
ahould b« fully addrassad in tba final SIS/BIB. 

Pagaa T-0i 

Tha disoussloB ralativa to COA Artlola 6 daaorlbaa bow tha 
abarlag foraulaa oouplad wltb tba Biblblt i ataodarda la tha 
COA daflna bow tba CTP sod SVP will ooordloata oparatlona to 
ahara both avallabla watar suppllaa and raaponsibillty to 
aalotalo Saoraaanto Tallay lo-baain una. Purtbar tba 
argtaant la aada on paga 8^ laft ooluan, third full 
paragraph, that all lo-basla uaa raqulraaaota (tnoludlag 
spparaatly thoaa ia tba San Joaquia Tallay baalo) ara balog 
aat if tha Bztaibit A Dalta atandarda In tha COA ara aat, 
baoauaai 

a. tba Dalta is domatraaa of all otbar In-baaih uaasi aad 

b. tba Dalta gata only tba watar tbat raaalaa aftar 
upstraaa uaas hava baaa aatlsfiad. 

Baaa4 oa tbla arguaaat. tba draft BIS/SIB ooaoludas oa pac* 
S-2, laft ooluaa, third paragraph tbat tba COA aaata tba 
aaada of tha araaa of origin. Both tba oonolusloa aad 
supporting arguaaat ara in arror aad ahould ba oorraatad in 
tha fiMl BU/IIB. 

Tha Dalta flow and aallnity atandarda In Biblblt A ara 
darlvad froa Board Daolalon 1*89. Thaaa Dalta atandarda 
wara daalgaad only to protaot oartalo prior rlghta aad 
baaaflolal uaas in tbs Dalta Insofar aa tbay aay ba affaotad 
by tha CTP aad SVP. Aa suob, tbay wara oalthar lotandad to. 
nor do thay naoasaarily oonfar, approprlata flow or aallnity 
protaotioa to aatiafy all upatraaa lo-baaio uaas of watar ia 
tha Saoraaaato aad Saa Joaquin Tallaya. 

tfhila salinity liaita la tha Dalta aay protaot DalU uaara 
froa aaawatar intrusion, this doaa nothing to asaura tbat 
upstraaa uaara ara protaotad froa local aourcaa of salt 
dlsobargas (suoh aa agrloultural raturn flows into tba Saa 
Joaquin llvar) potantlally ralatad to tha CTP aad SVP. 
Horaovar, aatlsfaotlon of Dalta flow raqulraaaota by tha CTP 
aad SVP doaa oot guarantaa tbat tha watar supply naada of 
all upatraaa uaara ara baiog aat or tbat aooa ara balng 







8. Paga 50, Bight Coluaai 

Tha last aaatanoa aorraotly atataa that iprll is tha aootb 
of hlghaat ooooara with ragarda to atrlpad baas spawning. 
This is praaisaly tha raaaoa for tba Board'a whaallog 
lisitatioa dlsouaaad ia aoaaaat Bo. 5 abova. 

9. Ph<« 51. Lart CalMai 

Tba last aaataaoa of tha saoood paragraph stataa tbat bigbar 
aiporta lapaot youag atrlpad bass aora In Nay tbrougb August 
thaa la fall and wlntar. Whila tbla aay ba trua In abova 
norsal watar yaara, tba Dapartaaot of Plah and Oaaa la 
baginalag to dlaoovar tbat looraaaad aiporta lo tba fall of 
dry yaars aay daaaco young baaa auob aora thaa pravioualy 
aipaatad, alaoa low outflow tands to kaap aora of tba baaa 
la tha oaatral Dalta (wbara tbay ara aora auaoaptibla to 
lapiBgaaant aad antraloaant at tba aiport puapa) rstbar than 
riuabad into tha Bay. Tba final BIS/BII ahould ba oorraotad 
to raflaat thaaa oaw flndloga, particularly lo vlaw of tba 
faot that tba altarnatlvaa balag aaalytad only dlffar la 
taraa of aotioa takaa In dry yaara. 

10. Paga 56. light Coluaai 

Tha third paragraph undar *lo Aotlon* aaaarta tbat oparatiog 
to Traoy atandarda ia orlttoal yaara ratbar than tha Bihibit 
A staadarda would not obaaga aiporta during tba psrlod of 
■aiiaua abuodaaoa of atrlpad baaa aggs and larvaa in tha 
Dalta (praauaably April through iugust). Thus, ths 
oonolusloa la raaohad that Bo iotlon. Caaa A would ba ao 
worsa thaa tba propoaad aotloa ralativa to atrlpad bass. Va 
dlsagraa aad ooasldar that lo Aotlon, Caaa A ahould ba 
daaartbad in tha final BIS/BII as worsa for strlpad baas for 
raasons slailar to thoaa glvan on paga 59 ralativa to tba 
advarsa lapaota of lo Aotloa, Casa A oo Salaoa. 

Tba flrat full laft-hand paragraph 00 paga 59 atataa tbat 
oparatiog to Traoy atandarda In orltloal yaara would 
looraaaa tha fraquanoy and aagnltuda of ravaraa flowa In tba 
lowar San Joaqula in April and raduoa Saoraaanto llvar flowa 
in April through Juaa. Horaovar, tba nait paragraph adalta 
tbat Inoraaaaa ia aiporta during Hay through July ovar tba 
Biblblt A llalta would not ba rulad out undar lo Aotloa, 
Casa A. Slooa Bo Aotloa, Caaa A appaara to ba oaat as tha 
"worat oaaa* altamatlva anvlronaaotally for tba Dalta. 
againat wblob tha othar altarnatlvas ara aaaaurad. it doaa 
oot aaaa logloal to aaauaa tbat aiporta would not Inoraaaa 
In tba abasooa of Biblblt i atandarda to tba datrlaant of 
young atrlpad baaa batwaao iprll and Saptaabar. Tbla would 
ba oooalataot with tba gaoaral ooooluaion drawn la tha flrat 
right-hand paragraph on paga 59 tbat No Action, Caaa A would 
ba aora baraful to Dalta flab than tha propoaad aotlon. 



98 



m 



PM« 97i lifht CoiuBBi 

Tba fourth parftgraph dlaou«a«s tb« luraau'a lataat to 
propoaa Llftlnt tba Oapartaaat of latarlor'a soratorlta oa 
tha Buraau antarlaf loto aatt lon|-tar« Matar aarvloa 
coDtraata oooa tba COA la aiaoat^d. Tba flaal IIS/Ill 
Bbould Qlarlfy wbatbar tba Buraau lataada to prooaad Mith 
suob a propooal la tba abaaaoa of a aaparata asraaaaat •Ith 
tba Dapartaaat of Hator laaouroaa to provlda p«r«*B«at 
protaotioo for Sulaua Harab. 



99 



OiRECTDRS 
^lAW m REOCKEfl 

RA/«( 8OA0MI jA 
mAARV BAuw^wjOh 

■nscPH a MMA& jn 

>3. H SmAMMCAO 



HovMMr f. I9BS 



M *M»i)A 1 OUNTV WATER DISTRICT 







Kr. David I 

OLrcccor 

C«Il(orvta DsMrOaac •! Vmttm I 

P.O. lorn MB 

SursMCo. CI 9SM2 



AGtUMBR. CmiAL fALLn PlOJKr/ITAIl WTB nOJICT 






Tha * 1 M»<a Cmbct Itour BlatrUc a^ymta arfoyctM of tka CMrdUUad 0^r«- 
tloo Acr*Maat Cor tba Caacral f*U«T fvojoct tmd tte Itau ttacn Frojack. 
rha a«r*^Nat la ■ — <■< Co rro*iA* lactaaooJ *«t«T OttvyllAa (or cho lt«u 
yatar Frejoct a^ (»r aavtra^MStAl rrocactlia mt th» talu. 

rtM DlaCTtct racalvM ftkMC tO forcMC •( il« fin Mtor aBwl? <■-» tk» ICaCO 
y*(ai Projocc. Tte nrnst ■iiial aatltla^aac U M.tOO ocn fool aa^ It viU 

■row to 42.000 ocr« foot U 1«M. Tkorafon. cko ' ii< MCa> aayfly ctot 

cna CoordlMCod O^ratloa i« r iiiiit MkM avftUafeU M tW >Cat* ItaMT rnjocc 
la axtroMlr la^rtat to tiM District. 

Tha Dlacrlcc io locacod !■ tho tas frf laco B«t At«o oiatf m aro rnrar^oJ 
•bowc tba ooll htm% of tta ftolt«. Uo aro »1«om4 tfcot cko Coor^loacod 
Oparaclo* A^rooaoat yrwUoo gTMCor FtotMtUa to tba Mt«T-roiAta4 wvlro»- 
■onc iB tb« teica oo ococod mm p^m 1-7 of tka fcilii^Miil I^«ct «tot«- 



ThwJk TOO fot tka npiiif lij u < 



IDT I. COTDDALI 



►«> 



NOTED 

N0V13S8S 
HHI 



tK. L . " • 



CEWTRAL VALLEY PROJECT WATER ASSOCIATION 



'>!■ >lk. tUm-. «>l-llii> SI., Mil 



HAim A. ■I.NMJi, 
I H II IJIM»lr, v.. . 

>*uuu .. «rn:iii(i 

IM« lAM-Wll 
llAMW^V M. IMASH 

IAM»-k Nil lia 
I KAMI kiaiil. I.. 

M«» r i:itM^iiT 
ItAVIH f. ijuuiiia« 
.»■ nNiK»ii, 

N.A.IUITIMI, 



Oetotor SO. IMS 



■otorl •. IrudbMC 

AvtlitMl $«cr«l«r)i of UUrlv 

for L«Ml ««d MUr MMHTCM 
Int.rtor Iwlldtllf 
H.ikliittoii, O.C. mw 

DMT [►■■^I'n III Hill 



* it«r.l »ccull»l im km »«■ •wrlu< or UK lUuicKtiM'i l,.i.rMl I. 

""TJ'T'' " **• '''~' "• i«u«i.i c«f c««,«urri;.. i^l, u 

•OMM U IK. p«rtUtl.lii, ,f MUr MMlIn ., >o.lM for I. liT 



(SWI 

lit <rt cirtaU y«i rMlIn UM 



" "* " r.«ylr.HMl (KkMlM ..AllAkllll.. i.l. ..._!..._ . ,7 



to Itr.ta 



Nt«r«st 

„„,^, , *; •■^••t •.•ll^lllt,; Ull HtMcUui. c«Iuli 1JI,|| 

^ f LI°?T* ""l^" •* "• ~"«l m* oMMt.l lrrl«.tl„ ^ 

f«r lk> aHtlklaf at rira Mtv S^»l/.- —w-i., u. luur^tiny 

15'f l".!?."* '"~«»»' «»• ««Cl«.l«. pTMl* 1 ftr> Mar UMl, MM 
«»• conlMrMtai It ,!«■ U a Of 1«««-l« M—lTlMUriiil.^lLr 







CENTRAL VALLEY PROJECT WATER ASSOCIATION 

fuj Ilka BUa.. »l-llil» tt.. 



ni. tJUiniMMu Ma« 



HAI-TM A. Ul^MtM, ftmm. 
CKCIL CAWrr, ¥lcm rraa. 
JKJUU) 1. MrrCNUT 

KUVKT 1. 



PtAMK DHW. Jl. 
ifllH P. ClliSUrT 

OAVia P. uuaiCMna 
iKj Puaiiuj. 

N.A.CATUU, 



kovtaar 12. IMi 

1. U 






Sft 4^;^ 




p<:^h:« 


B 



BiiTtau of Itoclaaatlon 

jaoo Cotcava Vay, (oca 11-213; 

SocraanU, C* HUS-laM 

». (vl Utnklar 
OaparUant of WaUr R*a«iir««s 
US1 S Str«t, kooa 0-4 
Sacrawrto, CA tsaii 

eaitlaaai: 

ttfaraiico It Hda to your Itttor attackao to CIS/(1> oateO S^tkrtar la, 
IMS, for tka pro»aM< CoonHnata^ Oporatlon of tiM Ftdaral CaAral «alltr 
Projact aM u* CaMforala Stau kator Project i«<cl< rtquotti coBiiitt on 
Cho rovort. 

(ki pa«t S-3, first fyll para^apk md first santanct, statos 'for Uw 
purckua of IntoHs C*r Mtar ky tut air.* nils skoulo 6* ck«i9td U: 
■for tka amual purckasa of Intaria and Intamttant CVP aatar by tka Sur 
aftar It has kaa» laltlally offara< to C«P Mtar contractors and • • *.* 
Tills Iii9fa i1 ad ckaaga appllts !■ a mattar of otkar passa^ai In tka roport. 

FiirUar, oa tka salt of Of aatar to tkt SUP your itttntlon Is calltd to 
Ult bsoclatloa's lattar of Octokar 30, 19SS, to Assistant Sacrtttry of 
tkt Inttrlor ■rsadbaat. « copy of Uls Itttar Is attached. 



Ht apprtclau < 



t opportwity U raipta* to yoar raport. 
Slacartly yaurs. 




iAQoCLc 



cc: 9fOar4 Of DIrKUn 







f 

lUr l.mlllaM up*l> 1 tiUl.aai acr*-larl tktr. is Ikv lusklklllly al 
CMTyltf tkt skartatt 'tr.ptrlad tf Hat laitll an C«P fa.lllli.^ .rv 
cuastmcttd for finia, uwllts. Matoar, Ikis l> nul tha prtu-al t.ut 
I" ^^ caalractars idMrt future ••tar aaadt art aH^mi It a lauality ul 
4.2 allllaa acre-faat aat aa aeallaklllty of 2.1 allltOH acra-latl lur « 
skarta«a af 2.1 ■1lllaa*acr*-(aat. 

far yuur lafaraatloa, tka retails tf ear laMttury ky C»P faclliln.'t m^ 
ttrrlc. artet art tktM ktla.. • spaclflc aaounl (oi . iln,lrli.l/i«)i.lj»-l 
i""i'i^ '• "T*"^ kac«ita Uls It i>art ol ll« lai^ti.tl., pr«.f»> Ai. 

lacluate lead clatslfUMtaa. crepal 7T . -» •- 

tf " " 



lead ClatslfUMtaa, crepplti 
Mtar, itiiwlc kaaarut mi 



patttraa, avalldlilllty aad ipialuy 



smiMn H siwiu m ini/ 

aitir 



i-SauU tai.ll 



Uittta Oaa Area ISkasIa CauMyl 

Foltoa Baa Area ICaclaalee af Fal 

Sacraaaau titer 

Conilat Canal ITakaaa CoMityl 

IthaM-Coluu Caaal (Slaaa-{aluu-lelt CoMMIat altk 

toae tenica U Saltaa Caaaty tia a ca^ltted 

Oat tetamlrl 
.Oella-HMdeu Caaal llacladlai MadaU Paall 
Vat Lull Caaal Sanica Area 
Sat rallp. ikit (lacledts M.OO* rasana to M»l«^.y 

aad Santa Cnu Cawtleel 
md-valler treap lOkaKklllt U (Marsfltldl 



lb,UUU 
/H.UUU 
44i,UiJU 
<>4,UUJ 
J<l3.ljau 



Ifti.UUI 
4UH,QIIU 
/7.0UI 



lOIAI. 



HkJ.UUU 
or Caatrtctart FIfa VaUr Supply ll«p.lm.«l> l.llij.uuu 



^ r!j?TJ?! *r?' " "" "^Oltaal Mltr r,.v.ir,mi.l ul ik. l..ls._ 
Wk C.MI Sartlct ArM. Co^l.tla, ^ ih, f.K„ ^,^ i^, ,,._ „. 
prvwj-l u^— at «W It.,!..., (WraMt. Cu».l,| ik..-^ i« .^.^ 

!JJ:?^Jir «<»<rt-a. Ill aetd c»s.*-r.l,u. ..lk..".,«.. i,r 

^r:i2rU.XIi£-^l'aii.5rt]2L"^ • Mr,.|uo./acr. I. . a^u^u 
.aariy tea -ca— '•^T^^'iiUm. la taaa catat Ike lacrt.M« s«r(», 
■«tr ra^irewata are u arfiat tJia kl^ caet ef 



:i 



100 







> ^lyKticaai tlaHM •« ikli rr<MM*tt>* •> UM <lt«JM< crturU Igr 
SuraM o( iKlautlaa uatraclla( i>IU iv CW sun. IM crllwU 
il«<l Kith u< frlvtllM liK utaclltX uaUMt tlaMMi tmr tk« ni^rt j- 
tlM o< rira. Isurls aM IMmUtait MUr w«*I<m U Um l»r cMlrjilvt. 
It don MM •wlata 9»'cMlr<cUn « C«f aMv »anUMrt Iwl •An 11 
cla<r txi lailir MMtl laUrta iM/v laUratlUM t^vIlM ka c4Mr«.lM 
!<■ thia sa • raullakU kul>. 

tl> caiclaM lk« u* criuria nprauM • «■«■■>!« kM)i lor coali«.lla( 
<i>i rrpmoM • coMoawt ml our iiai Ul>. Ho kljklr i iii— i m y«ar 
wprovil or Uo crturla. ><ar lopriial a>a Ika camcirTml llltlat ••> '■« 
•uralorlM •• nr aotor lalot at II froaiaa taMtaailal talUiJiali la Ua 
prewat aMor caMlllaat of tko Coalral Xllor. )' 



ail I 



' rof Ijr te tklt oxtrvaly l^url 
Slacaraljr yaarft. 



^i 



Ulpk A. lltua 



FH 



Oclobor JO, lU»:t 



I CKimUL VALUtT MKUHLT MltJt Aii:Nk-l ATltM 

PropoiKrf Criteria aad PrlaclpluM Gowt?riiiy 
I hu Coatractlag tor \h» t—»UUg CVP ^ater ihipply 

irtsctlv* stsca Jaavsry i919, Ck*r« kaa b«aa a ■uraloriua lapuxjil by 
tha Saoratary of tba latarlor oa rurtbor coatracllac lor lira ix-uiral 
Vallay Prujoct (CVP) aatar aupply. Tha Coordlaatod Oporul tuan 
Agraaaoat (COA) iMa baa« ^^rtt4 to by tbv CVP aad Ibv Stulf lui* r 
Projact (awP) for tba partltloalai of tba rira yluld of tho Prujv4:i« 
aad for akarlag of watar raquirad to Maat the Delta water quality 
ataadarda. Upoa aaocutloa of tiM OOA by tba Durwaa or Bi^cla■at t«>a 
(BCNI) aad tba Dapartaaat of latar RaaiHirofM (MK). It Ih umpt-'vli-tl 
tbat tba ■oralortwi atll ba lifted aad tbaV tha BOH alll prtM:4.H.<d 
■Itb eoatrmoiiag for tba raaalalag flra CVP aatar wupply. 

A. Coatractiag Katlty : (l^iallf Icatloaa) 

fba t«#a "CaatractJflf ^KJCy* am aaraJiM/Ctfr ii*Mrf ■».*»■ *a .«|c«k.'v 
^acAarJaatf a* '*■' ^^ ooauact tor « CVr *«(«# auppiy, tritltL-r 
4itmMl9 aJtb tba iUcad Mataa ar caroapfe aa afvoucv lormid tor 



la aitbla tba Goagraaaioaally autborlited CVP Mcrvicu 
area; aa4 

ia vtttala tba Place of Uaa r»i u^iiadod by tbo Ci-alrul 
Valley Project fatar Asaociatloa (CVPVA) nad ;i<tiipi<-d 
by tba BOa la Ita patitloa duti-d SopKabur lU. I1W&. 
to tba Btaio Vatar taauareuM aiatrul Ikutrtf (SVHUUt for 
uuaaol Idat loa aad ualargtMi*at or thii I'laco »l Umi- undi-r 
uaiatlag CVP paralla aad llueamTM. Tbo c4Hidllt«iaK t>r 
tba ^rslta aad ) Icuaaav approprlui<-ly riMnifcatKi* IIm- 
*K>n*aty uf OrlgIa** aad **lulitrNlK<«l •■n>li-«-l Hm*** |ir>tvtKi<Mi>. 
M* (ladMMlliid la lb*) •«L<>r UmIc. iUti i>MiN lufiiKS :itMl 
IMtlOoi. ami., niN|KM:llv«>ly ; uaU 



IH 



vllllag tu oo^ily «llb the pnivii 
jlaaatloa ■uform act uf IM3: aad 



tlLiih <>l t Ih- 



A. 

6. 



agrwaa to aao tbo aator fur Ibu prDwrvul Um mI •■■^imI- 
lag dovaloyad laada; aad 

agraaaio aecapi aa allocatioa or aoa or luklii ioaal 
f ira CVP aatar aapply baaad upua aaMuaod rul i ui i 1 i- 
aatloa of tba aata yield of Ita grtMiad vatur aad lucul 
aarfboa aapply ooaaldarlag qaallty aad ucoaualca: i*ad 



M 



^ 



u. |Hgro«w tu a duvulupauel purlud altbla IIm «^«Nilntl liir 
u tuna or aot tu oaut^id 6 yourH la abU-.b l<i tia«i:Mt«r a 
coatraut, aad Iburuartar a balld-up p«irlud t»t eaiur 
dollverloa aad rupayaual aot xBCfMNllag 6 yimra. 
(Cuaerally a coatraut uatlly alll bo ruqulr«td tu «ial<>r 
lato a cuelract altbla a purlod or 5 y«ara aad fully 
utillaa the coatracted aater M«pply altbla 6 yuara. 
Huaavvr. If a uoatract la i ■■■uiia^i iid alihia % yuara, 
a 5-yaar pvrlud alll bu alloaud for t Imi dovttluiaatial 
period. Accordlagly, Ibu lutal 1 lai> anuld bo 7 yt-arN), 
The afaovu bwlld-up *»t 5 yuan* In rolata'd tu irr tifitt loa. 
A loager period alll be retialrod for aualulpai aad 
ladaatrial aatur coatrmctorw. 

Ttoi |in(poNi>d orltiTla for allwallua or ib«> uaiiMtl rarlxd I t rm fVI* 
aalcr wupply . la ordar of priurliy, ahall ^> aM rolli»aM: ~' 

II. I'rtii rtt low : 

1. A ooatraotlag uallty thai la aa oalutlaa loaii-lora t'VP 
i-natractur la aoi4 of wat«>r HWpply auipwalat l«*a um a 
ruault of roduoed uaablu groaad aatvr ylvld, a 
raductloa la local aurfaca aaler aupply, or aa ai-t^i'pt- 
abla laoluatoa aad bavlag nvallabla uapaully altbla Ita 
ealatlag dlatrlbatloa ayalea. 

3- A coatractlag oatlly that 1m allhia aa awordrariod 
groaad-aatar baala aad baa pruvlouwly b*tld a "nlHtrt- 
ler«** or "tiaporary" CVP aater aurvlctt vuatrwvl aitb 



3. A coa trad lag uallty that baa a iM-adian uppl liul loa 

■ itb Ibe DOB ror a CVP allui:alloe aad baH I Im> miMiblllty 
of applylag addltloaal aati'r uapply to n-aMiaabltt 
boauflclal uao. 

4. A coalractlau «>altly Ibul \h Mt-aly lorai^l •itlMttti .■ 
ftruvluuM uualrautiag rvlMlloaHbip allb tin- IBM lor n 
rvp aator aupply. 

IniiTla CVP lalur Supply (lator wupply uad«tr utui ru< I ImH 
nut boiag uaad by llw ooalrai:turk uluall bo auU4- uvullultlo 
lu a coatractlag uatlty aubjucl tu ru«-Mll, la ttHtforatly 
«ltb tba aaaa criteria aad ordor or prl«trtty un «mii I luttd 
ubuvu for rim CVP vatcr aupply aad allb aa luldll itta^tl 
iiriurlty aa fotloaa: 

&. The Dapartawat of Water ltuMuar«tuM r»r tbtf m* hh 
uavlaloaad uadar tba OOA. 



K teflttoat CVP »alur aupply aha I I I*.- mIIui'uI>.-U 
llualag order %*i pr' 



r flupitl 
lorliy: 



I. A coatractlag oatlly thai i^uafoi-aN lo ll •wm A.I 
tbruagb A. fl. aM llalutf ubuvu 

S. A coatractlag oat Ity that lu ellbia aa uverdrallud 
grovad-aater baula aad baa tbv capability of uccu«i»- 
llablag grvaad-aatar rocbargv. 

3. A ooatracilag oailty that lu la aeod or iuWi14mmiiI 
CVP oatar Mupply. 

4. Por 0.1. flub aad Wildlife Survlcu. c^iiirnraiu 
Dapariaoat of flab aad Caau. aad llldliru refuse 



Por aabaaoeaaat la tba Trialty River Plubaay mm 
re^irod fnw tactual atudy boyoad tho 130. OOU u 
faat aaaaally laalu4ad la tba OOA yluld utadloH. 



-101 



(XaCCTCHM 



^£ir mmisiifflraw 



Ootatar 14, 1*M 



Zw ^1^ 



t- 



■agloAAl InvlronaaatAl of(ie«x 
0. 1. Buraau of lUclMUtlon 
2000 QDttsg* Hay 
•acrlaanto, Ol »11S-I»e 
Ittni lob (chroaAu 

OBftr Hr. Bch r oad T i 

I^ABk y«w for fuxvlAhiag • copy %t tb« «r^t IXS-IXS t*r tiM 
Ceerdlootod Oparotlaa *gr f «nt. I awiM Ilk* u •alalt 
tba fello»la« oaaawit r*garaia« !>«• t-I of tk« •• 
IM i c rlptloa o( tbo »npo<o4 tetlaa UuagrMl 111 

Tbo ••«<••£•• of tte ■toratUa- u AoMrlbod 't* fl»t BMt 

tho I I m « lo uia orou of orl«l>, loclodlag tiM Dalu 

Only Umb is imtar o^portotf froa t:bo Dolta.- 

nila la a fala* and Blalaadlno atatasaat and ateold ba 
corroctad to road 'to flrat aaot tbo aaaila of t^ Dolta 
•atar quality ataadarda aad tlo« r«9iilr^«ata ooatalMd la 
lamiblt ». Tha roMlala* oatar aivply la dry yaar* irlll ba 
dlatrlbutad aTaaly to all aaatrastora ra«*i«la** af araa 
af orlglB ooaaldaratloaa. * 

It aboald bo abBtdaatly olaar ta aayaaa riilllaa lahlblt ■ at 
tha aoroaaaat tbat aatar mil ba aiqiartad trsa tba Dalta la 
•atar abort yaar-a althout priority t* tba araa af arlgln 
'«*Pt "^ Dalta aad vlthoat aaaUa* tba (all aaada af tta 
araa of origin aaara. To aay It la aat ao la 
daaa aot chaaga tba facta. 



.^^"SSL-^ 



Ell 



larl Vliitllr 
Hit 7 

• r 13. IMi 



J. Tka Afraaatat frarlMi far ■porailaauly (00.000 tcra-faat af aatar u M 
*aa4e aMlliblt* fraa tha Caatril <lallor rra>act afur aaatntlaa af tka 
«pi»i«l. Tlia Draft [IS/Cli <l>ci>ita< laitlkla aiai af Ull aatar, tacladlao 
••)a ta ataar caalractort. Tka Draft CISAII tkaiiK laclada aa aaalyali af 
tka kaaaflti to tha lay/Dal ta attaary If tkli Maant af aatar aai aaad u 
<a»ra>a aaur aaalUy la tba altaary by allaalaf tka aaUr U f1aa tkroafh 
aad aat af tha Dalu. SlalUrly. tka Draft CIS/Ill ihauK Uaatlfy aarana 
affacti af aafltlaaal aapart af aatar. aartlcalarly aa itrlpaa Uii ••< 
talaoa. Tha laaacti af radacad aaaati of aaUr la tribatary rlwrt aad tha 
•ay/Dalu aitwary tbaaW ba fally avalaatad. 

<. Tha Draft EIS/CIH ttalaf that tka affacti af tha AgraKaat aa Salua Hank 
•111 ba adarMtad la tka aarlrwiaaaltl da<Kaati aa tha praniaa tuliua 
KariK «fraoBanf. Thli li aot accaatabia bacauia thara li aa faaraatta that 

tha fMtara aarlraaaaatal dacMaatt alii ada^ataty ■ddiill aaUr auallty aad 
flihary ataacti af Salua Dank aatar aaillty, daa to tha Bgkaili af tha 
p^Bosad 'SHltaa Nanh Afraaaaat* m aator^al. Tka Drift CIS/CI* theald 
faOy daaaant tha affacli af tha Caordlaatad 0»*ratl*a kgrasaat a* aatar 
Wlllty aad fllh la tka rlclalty af Salwa Narlk. 

t. Tka Drift CIS/lit ihoald laclada aa aaalyali af tka aaaatl aad aaalrwMatal 
affacti Ihcraaiad ifrlcaltoril dralaafa fra tha Saa Joaqala Villay ratw1tfa| 
'raa tha lacraitad aitar dlranlaai to fallay a^lcaltora (atllbla aftar tka 
aiactttloa af thli Agraaaaal. 

Saaclfic C^arnti 

I. ta paga 4t, thara ll a aararapk CMKaralag Dalto aatflaat u Saliaa lay, 
San Fraacltco lay, aad to tha acaaa lUtlag thit tidil laflaaacai taod to 
avarahala frath aatar fTe« oaci thay gat bayoad tha Oaltl. Thil lap) lai 
thit Dalta agtflon ira lail|hlflca>t caaparad to tidil laflaaKai. Than 
l> no deaawntitloa ta ihaa that thli coacUilan li trM ind apaaara ta ba 
caatrldlctory to racant findlngi concarainf tha aacaillty af flaol to 
itritify varleai pirti of Sin Friaclica lay. Fraih aatar flaai ira l^ortint 
to tha hailth af tha lay. 

I. Oa paga U, tha itiuaant li aada 'to tka astaat that my aitar iirad by 

apariting for tha Tracy ttandirdi rathar than for tha Cthlbit A (Oaclllen 
14n) itiadardi aaald ba ralaaiad laitaad af ratilnad In tha rasamlri, tkr 
aavlroMantil caaioguaacaa of no ictloa aoatd ipproack thela of tha propolad 
action II fir ii rivan ind rasaraoln ira caacamod.' Thli itotwant My 
ba corract ^r rlran ind ratarvoln apitroM of tki Oalta but li not tnia 
for tha aattam Dalta ind tha altaary lyitaa doaaitroM of tha aaitim Oalta 
ahlch aould ba advanaly iffactad by Iddltlonil diranlani fraa thi Dalti 
raulting fr^ a ralliltloa of aatar gaallty Itohdirdl. 



Water Agency 



Contra 

Costa 

Couty 







(arl klatlao^ 

lapartaant af Iktar Raaaarcat 
jni S Straat, laoa D-4 
Sacrvaato, U tSlie 

tiar lb-, dlallar: 

Tkli lattar ll to lalalt ci^Mati fraa tka Coatn Coiti County Uitar Aaancy or 
tia Drift tnrliiiMiiitil lapact Sutaaat lad Enrlraiatntil lapict laport llli/llt) 
m tka pragaaad Caerdlaatad Ogaritlaa of tka Fadaril Cantril Villty frojact and 
tka Callfarali Stata Iktar frajact. Tka Coatn Com Coanty bitar Aprncy li 
gaili'aad by tka loird af Saparvliarf af Coatn Caito Coanty. Aa oral itot«cnt 
tbat aal lotbarlcad by tka loard of Saporvliori aai prataatad at tka Octobor 22 
aad laaattar ; pabllc koarlagt. A cagy af tka lUtsant li attackad. 

Tba Caatri Caato Caaaty Iktar Agaa c y fapporti tha Caardlaatad Ogaritlea Agrawant 
aad m 311) alrich aaald awtherlxa tha Sacratiry of tha latarlor to aaacwtt the 
Agraaaaat. Ik aata that tha Caardlaatad Ogantloa Aya — nt lieu i ciBltaanl 
by tht fadaril gavlraaant to Ihm raaponilblMty for aaatlag fwturt alter 
WllUy ragalraaatl lat by tha SUte hatlr laaoyrcat Caatrol loird. Although at 
aipact tkata aatar gaillty ra^lrvMati to ckaaga altkla tka aoit faa yairs, ae 
taal Ikal tka Caardlhitad Ogaratloa Agraint ll a lUp la tka right diractlon. 
, aa da kara urn caacarai akoat tha Draft eu/tlR 

C^Maato 



1. Tkraagkaal tha diMiht, thara ll aa atHaptlaa that Oacliloa Idas aatar 
gaillty itoadardi, ahlch in laeladad la tha Agraaaant, alll praUct alter 
gaiMty aad athar aarirwiHntal «iilltlai la tha lay/Dalu astoiry. he 
■troagly diugraa altk tkli laiiaptloa. Tka past laaaril yaira kara ihovn 
tha taadagaacy af tka aatar «ullty lUadards la Oacliloa IWS. Also, 
Daclllaa lags aii rajactad by tka Coarti ai lagragarly proKlgatad. If tke 
Drift (li/CIS ll ta aata tka altiaptloa tkit Oacliloa IWS idaguitaly 
protactt aarl raaaaatil valuat, datallad lafaraatlon aast ba provided to 
daoaaat tka nitdlty af tkli caaclallon. 

t. Aa analytli of tka rarloM aatkodi by ahlch tka Agravant caa ba taralaited, 
•Itkar aallitarilly or by both partial, ihould ba erilaatad. Tkara appaars 
to bo aaay aayl for bath partial to taralaato tka t 



*■ pafi H. tbtr* li a Ikart dllcaaita* caacaralag Friant turn aad Mlllartor 
LaU, Friaat 9m It locatod en i itns trikatory to tke Sin Joaquin 
llrar. Tka Sia .kiagain «l»ar ll aaa of tka aijor tributirlei to the Oelti. 
Aa aiplaaatlaa ihoald ba aMa ll to aky MUr direnlon ficlllllal on the 
Saa Jaagala llrar (tach ii, Friint Dm lad kaa DallaMS Dm) an Mt goremeo 



by thit AgroMMt lad idiy thay an Mt aipactad to contribute to liy/Oelti 
••«*' aaillty. TkoM ficllltlal could pliy i Mjor pirt In l^>n>lng alter 
Mallty In tha Saath Dalu. kaa-coaildaritiM of aajor itoriga ficflltlei 
aa tka Sm JmmU (allay It a aajar mIiiIm af tka AgraMoat. TM aarlroa- 
■Mtal r MiagoM LH af tkli mImIm ikoold ba filly addri i iad. 



If yaa kara aay «aitlMi. glMta caatact Daaa MIto af tka ( 
N p irtMit at 41$/]7I-n71 . 



•Ocl 
M.l.alatlar.tll 



ally Davalo^ant 




iul E. Ililanny, Chief Enjiney 
CMtri CaiU Cawty hitar Agent, 



AttacMant^ 



102 



NORTH DELTA WATER AGENCY 




-4&i> 



». UtiOtrl Schrodv 
Burcw of Recl«Mt1o*t 

2800 Cottift y«r, tarn 11-2137 
sacriHnto, u tsa»-ia9e 

nr. iirl Ulnklir 
OqxrUnt of MUr teuyrcM 
32SI $. Strott, llooa D-4 
Sacramu, U «Sai« 

CitinXmm: 

■efermco ti aMt U yaur littar ttttcDM to EIS/EII Oatod SopUtfxr 18, 
1985. for tho propoiod CoordlnataO Opornlon of tM Fodoril Cttitnl Volllr 
ProjKt and tho California SUta vaUr rrojact atitcli rasuoilt comwici oh 
tht raport. 

Our coMaMi tIMKiU M coMtOarX ai a Joint raaponaa 0> Ikll AgoKr "* 
ina California Cantral «allar> Flood Control AiMClatlo*. Thw aro ai 

follOKl: 

- On pago SS - Dm raport Indlcattt a boMflt U Oalta A»rlcultur« 
bacaola of tM -Hyaraiillc Connnrtlom to th* OoUa Crosi Channol." 
Thera It no Indication as to tha projact't oparatloni li^act on tht 
Oalta lavaa ijntan tJut lupport tlio floM to too Tracy and Dalu 
I>um1nt Plants. SMorally, tha cyp and SHP aatar tuppllas folloa 
CKrough fro tiM Oalta Croat Oiannal Into Snodfrait Slougli. Hortk aa< 
Soutn Forts of tha Wtaliaaio •l>ars (adjacait to lylar and Statan 
Islands) and soutlward across tha Oalta to tha pul^ln] plants, la 
oair analysis thar* Is a lack of accounting for tha lapact of tha mom 
dlvarslon on all of tlw Oalta lava* lystam. Tow tttantlon It callM 
to tha July 19. I9M lattar froa tha DIractor, o^iartMnt of Uatar 
Dasourcas. copy attachod, lAlcli acknoitladgM tha ■contlnilni la^acu 
upon tha channals." 

- On paga M - Undar -Saapaga' It It acknoaladgad that at 'critical 
stagat* along tha Sacraawito lll»*r that saapaoa •III occur to adjacaat 
lands. This saapaga lapactt aarly far* plantings aid daltyt harv«t- 
ting datas. Alto, thar* ar* l^>acts on SacraMnto Rl»*r laraat Md 
adjacant fars lands and orchards Mcua* of Ui* projact't operation. 







- Ch paga ia - north Oalta Matar Aoancy Contract - Tha aatar quality 
raqulrannti of this tgancy as provldad In tha contract »1th OM ara 
Idantlflad and ua ara gratlflad that tha Oapartaant Is bound to tha 
contract ragardlass of fuUr* changas In Daclslon IW5 standards. 

Furthar undK- this Itaa, r*latl«a to construction of Sharaan Island 
facllltlat. It should b* acknoaladgad that aitin^tlon of oparatlon 
aad aalntanaaca hy tlw Agancy or transfaraa aould b* at Stau Wtar 

ProJ«ct a wn an t a . 



laU tka opportunity to ranlaa and coaaant on th* Draft (apart. 
S1nc*r«ly yours. 



^n.p^ Gtti;r 



im 




OePAKTJMENT OF WATER RESOURCES 



JULlltSM 



<^r . Rlch««l A. Catino. 
Hortb Dttlta Hatar Aqancy 
921 - llth 8tr*«t, mum 703 
Sacraaanto, CA ffStl4 

CMar Mr. C«tiaoi 

Rei Chiwl woclt In tb« Wortii Dalt* 

ntls l«tt«r is « r«spooa« u> lasuaa rata«d at racaat •••tinga 
attandad by Dapactaaac ataff and Kortk Oalta Intarasta. 

Tha Dapartaaot raoo9Blaaa that tbara bava baan continulnq lapaeta 
upon tha diannala of tha Noluiliauia ftlvar oauaad by tha fadaral 
croaa cbannaL through wbioh watar oi tha fadaral Cantral Vallay 
Pro]act and aosa watar of tha Stata Hatar Projaot now flowa. Tba 
Dapartaant of Matar Kaaouroaa (DHI) will attaapt to addraaa thla 
laaua In conaultatlon with tha Aqanoy, ftaalaaatlon Dlatrlcta and 
landownara and aaak tba oooparatlon of tha Unitad Itataa buraau of 
Raclaaatlon ta tha analyala aad aolutloo of aKlstin« problaaa. 

Tha Dapartaant of Matar ftaaouroaa la alao awara of Dalt« landownar 
concarna that In prooa«din9 with a ttata projaot wa would attaapt 
to Halt our raapooalblllty for aroaioi oontrol to only thoaa araaa 
of actual oonatruotloa aa baa baaa tha blatory of tba fadaral oroaa 
channal. nia ia not tha oaaa. Ha intand to analysa and asaaiaa 
condltlooa in tha Dalta to ba aura wa do not cauaa flow changaa 
that oould ba raaao a ably oonaldarad to oauaa aaaavrabia advaraa 
lapacta wltboat altlgatiaf aueh iapaeta. 

It ia raoo9nii«d that aiiatlnt prallalaary daaifn informatian aay 
ba inauf f iciant to aceurataly projaet valoaitlaa and ataqaa of 
channai flowa. Bowavar. aa datallad daal^i and conatruction 
procaada, tba Dapartaaot will pcavaat or oorract aroalon or aaapafa 
problaaa attrlbutabla to tba pro]aet. Ibould oparational 
•iparianca of ooaplatad worba ravaal uoforaaaan lapacta 
4Ctributabla to DUI aetioaoi thay will ba oerraotad. 

Tha oootraot batwaan tba Stata and tha north Dalta Matar Aqancy 
datad January 1%, Ittl. provldaa ia Articla ( (or tba rapair or 
allaviation of any aroalon or watar laval Lapaota oauaad by tha 
Stata Hatar rro]a«t upon uaara withla tha Aganoy. I oonour that a 
■upplaaantal agraaaant with tha Aqanoy abould ba aqraad upon prior 
to conatruction of ohannal work la tba Hotth Dalta anviaionad in 
Sb 13t* to li^ilattanc thla oontraot provlaloa, ailitinf Hatar Ooda 
aactlona 12(27. 3. 12«27.4 and aaotiOH 12127.3 propoaad for 
SI 13t». 



Dartlt. Chalraan, HOM. w/«nclotura 
^ C. (Tla) Wllion. Prasldant. aVFCA. w/cnclotura 
J«ni Shanki. Raclaaatlon Olttrlct No. 38. v/tnclotura 
Oavtd firwilchar, Raclaaatlon District No. 106. M/anclnura 
fi«>r9a l«sy«, Eiq.. Oowtty. Irand. Saywur I Robwar. w/aKlotira 
Don KlanlM. Mirr^y, Sum t KImIot. a/anclotura 



M 



Mr. Nichaai 
Pa«a 2 



Tha aupplaaantal agraaaaat batwaaa tha Stata and Uia Ayancy, and 
tha Stata'a coaaltaant to ■aelaaatioo Dlatricta ami landownara 
abutting affaotinq channala, will covar at laaat Uia foilowln<| 
pointai 



(•I 



Oaaiqnatioa of an anvloyaa by OHK to ba raaponaibia 
llaiaon with tha A^aaoy. ftaclaaation Oiatcicta and 
landownara. 



for 



(b| Appointaant by tha Agaacy of an advisory ooiMittaa to tha 

Dapartaant on auc* aattars aa tba aalaction of projaet daaiqn 
crltaria. conatruction apacif icationa, alignaant and 
right-of-way raquiraaanta. ThU would includa racraational 
(aaturaa. 

(o) Proviaion to tha Aganey by DMt of all appllcabla racords and 

fllaa ralavant to and Indicativa of flowa and aaapaqa froa tha 
channala in tha North Dalta. Ttiia Inforaation will ba nwta 
availabla prior to tha agraaaant U raquaatad by Agancy. 

(d) Proviaion for dataiting aaintananca st^ndarda ami approfjc iat« 
sharing of financial raspooalbility for aalntananca anong tha 
Dapartaant and Raclaaation Dlatrlcta. 



It you naad (urthar 
(91ft) 445-4SM. 



llnoaraly« 



plaaaa contact aa at 



David H. Kannacly 
Diraotor 



_i^ 



103 



liD 



Northern CaMon^ ^w«r Affancy 



(•lii iii-tno 

«lil*ir 11. IMS 



IbrMii of taclMAtloa 
0»p«rtm«t of laurltr 
2M0 UttMl u«y 

itcrmmu. U MSS 

>••>«: r ii I II a CIS/Ill - KmrtiiMM ^vMlw 




"^-vy* 



/^^ 



t*. r««r<1 CaMril lillt, frtlKt (CW) M tM Callforala StIU Wur fr,l.ct 
TJ. CyltMUr I«:.ij,c4l C<»1tu, (toMltUt). i*ia ll O^M .f M X.IIM 
Ui wiura knt tav •Mliltu-rtloii'i >i»f...« c» >M*r cuMwi n.ii n tte 

laplMMUtton oY Ui cMopti la uli ^r 1. TW Co^luTu mn 

amj*rm0t, tamytr . tA.t u. CM >». «ot pr*vl<M lorflclaK cvulMrnlia U tkt 
aulas »fflcl»« tamtr mt^t\m »f u« Clff 

*• •• «•«*■•. tlB CiBlttM 11 amanm* uut ^ Ua aalaclMlai •< »m lkln>i 
!• «#|Mii<li (. Ui tutu of ta> «lo<iM 6« ot Ua II.. tlH VM-atloTitllM 



»"^»"^. "M Vita lacarttla. Tmi rMalud mcwm of Ua ittu Wur 




lioa of tM offact of Ua 



actloo 



TM •aft (IS/EII auorti tint a ,_ 

•••'»• "0 "Ctlo. alUnutlM oa tia C»fi «o»ir "Br»iiurtla.''^Z2TlITlir 

IMIC.U. « .i„f,c-« aiffar^ca I. .Mr.^ «!sr,.ir^':„srtJ ii « 

»c..«rll, <l.,«t. tkoM flMI.^. M uim, tlat tiuTtll.. iJTJT E 
rokati, lo^lcato wtor aarafa aoMal ponr |Mr.tlM xtMtlal. IrMtlif Ml 




OH 



■urcau of ••claaBCion 

2800 CotCAgs Iter, looa W-2137 

SAcroMnco. CA 9S02S 

Acta I Bob Sctaro*<Ur 
Daar Mr. ScbrocdaE, 

ACtachad you vlLl fiad cb« co^mdci of cha San Juan Suburban 
Uatar Dlacrlct oo th« draft in "1 rniMiiii \\ l^acc •tac^Mnt 
par raquast of tapCa^^r IB. 1985. 

If you hava any quaatlooa coocaminf cha anclotuxa, plaaaa do 
not baalcat* to call ^. 



Sincaraly yours. 




■^3 //* 



1. BAISCM 
ral Moaafor ( Sacrotary 



e*ftfJi:/JO 



Pafo Tim 



MIoMt la tAlt MMHT will tlw UMM a* tacraaia in tM ^^joct topondable 
Cipacltjr of tM CW. Mramo tM turawi OMild rocatr* fwli cro4U for tM portior 
•f Mo MToM* oocor tMt CM M ani la mmi to Mot Oolta Mtor Qualttj' dOMiMi 
M rocofolia tMt MM MIoMt Mtor ylola li. wltiMtely. plaonod ontlroly for 
la-Mila MOO. la i Moiii'. i«tl1 coavoyaaca facllltlat ara caaitryctoo and water 
MaaMj lacroaao to aUlaoto coa41t10M, a portloo of Mo MIomi vator could bt 
aaM a>allatla U ao*t MIU Mtor gualltjr liaiHi. Moa| otMr Cl» rawlrMCfiti. 
raultlof !• pauatlol fav t^maMU olw. 



McWM Of CM Mtoaclal Maafit c« tM CVT't poMr production CMaailltloi (of 
Mflalof Ma MlaaM m • faMral ficllltjr 1> tM CM), tM CoalttM ttrongi, 
racaMMM tMt, «M laalaaMtatlM of tM CM ky tM Ivaao aad CMI, trtlclts 
14 aad li M lanaM aa a xalclo far M«oclot<oM u iacloM Ma MIoaaa Dm ai 
• faMral factlltjr aa aaw aa Mulkla. 



uci«£L a. unrwiin 

Ktk Maaral Naatfar 

OMIrMa, nr TacMlcal CMilttM 



M(ar *. 

Omo Cal^ 
Bo«a Mttttoa 
fiaorfo Fraaar 




S*M /Um SU m i*m Kfmtem VuCUet 



It 13, IMS 



catoKi t or THi lui jiua suiuuu uatu distiict cm the deatt 

»»VI10tE» tAL D PtCI ITAIOmrT/UFOIT COOUIIIIATEI) OPEIATION 
CDTIAL VALLIT H0J1CT/ST4T1 MATES flOJECT. 1 lii 



Iha laa Juaa kibnrkaa IMcar Hacricc raealvao Ito aator 
aiiyplj (Toa rolaiM laaarrolr. Durini dry ;>arlado. tho loa voter 
la»al wlcbla FolaiM EaaaTvolr aakao |H^>i<i« DKOooarr to convoy 
Cba MatrUf • aatar aupplj to lea rataraon Uatar Traataonc Plant 

Iba rroroaad acclos of cha Coordlsatad Oparatlac *«ra.«nt 
•111 hava a a*(act*a omlxoaaaoBCal l^uct oo tlia raiguiTaMiit to 
yrovlda a4dlctooal r<Mpla( Co obcaln cha Folooa laaorvolr aaccr 
aupply CO Baac cha DlacrUc'a near aaado. Iba loaor tho Kaaorvou 
tMtar laral tha ana | W M> «t n aad hlgbar haad Co pi^> ogoloac. Thl. 
la aac out la tba C(U fc^ a r y. pa(aS-6i Tha 00*. Pago iO. Col 2. 
Paragraph J. llsa 10 acacao "...piMplng ra<pilmanta for water 
dallnra^ dlzactlr froa Polooa Laka aould ba iacraaaad aad aCM 
of cha aatar uaara ralytag oa chlo oourco could oavarlooco Mire 
aavara aatar ahoTtagaa." 

"lacauaa cha Propoaad Actloo aould cc^t a graacor aaount 
of CVP oacar to Oalta uaa and outfloa than cha CVP alghc ocharviae 



104 



0^ 



relcas* for this purpo«« la critical yttara. critical jmmx «at«r 
level! in CVP raaarvolr* uodar th« fropoaad Accloo could ba lowr 
than thay oisht ba imdar tha Mo Action altamaclYa. Critical yaara 
occur laaa than 10 parcant of tha claa. and oparatloaa during ochar 
yaar Cypaa would not algnlf icantly affact atoraga changaa. Uowar 
raaarvoir lavala at Shaata, Clair bi(la, and Polaoa Lakaa could occur 
Accordlnc to tha oparating aaaia^tiooa uaad la thla raport aod 
[ughc advaraaly affact aaachatica and racraatioo at thaaa lakaa.** 

Tba COA auggaata no aigalficaat luiai r oa pu^aga raqulraaanta 
or watar aupply aa oo mitigating aaaauraa ara auggaatad. 

It appaara froa tha oparatloa critaria uaad for Polaca laaarvolx 
that racraatlooal and fUh ralaaaa racaivad conaldaratioa vhara tbm 
inpact oo doaMatic aupply waa practically Ignorad. (^aga 11). 

Paga 94 - PoaaLbIa Coofllcta vlth CovanaaBtal Plana 

rha Miltl-Diatrict Plan la to aupply aupplaaantal wntar to 
HcClallan Air Porca laaa. Borthrldga County Vatar Diacrict. Arcada 
Uacar Coapaay . Llo Liada County Uktar Diatrlct, Ciclaana Utility 
U3<ipany, Saa Juan Suburban Uuar Diatrlct, Cltnaa lai^ca Uatar 
Diicrlct. Pair Oaka Uatar Diatriet. and Orangavala Mutual Uatar 
Co^any, co ravaraa tha daclina of tha growd— tar tabla and raault 
Id a dacraaaa la aoargy conaiaption and «lilch would allow Cha 
plaimad davalopaant of northan Saeraaanto Comcy. Thia pl^ haa 
baan approvad by tha Sacrananto Cotmty board of Suparviaora . Tha 
Lncraaaad piling and dacraaaad aupply aa atacad on paga 10, colt^ 2, 
tfould ba ln)urloua co chia local gmaii— r plan. Thia la contrary 
CO cha icaCMMnt taidar "Poaalbla Conflicta vlth Govamaancal Plana. ** 
•ac forth on paga 94, colusk 11. 



16 



In concluaion. tha Saa Juan Suburban UaCar Diatrlct ballovaa 
tha lowariag of Polaon Laka lavala and tha raductlona In cha wacar 
aupply aa axpraaaad in tha IIS itnr iManr. paga SO. coIuhi 2, paga i, 
cooatitutaa a nagativa aoviraanancal Inpaet of cha Propoaad Action 
of tha COA. U« raquaat nitigation of thla Inpact. 



SlAcaraly, 




4-S //,.^^^ 

B. HAHSn 

al Managar k Sacratary 



[iB SQribaorQVUMjWbbarOUrid 



^ 



^ ^^ 



izj: 



nt. Bok Sckxoa4«C 

a. 3. ftar*a« at kaclaaatlaa 

!S00 C0Ct«C« My. ftooa l»-ll]> 

SKTMMIt*. Ca tM2S 

I>au ttr. 3cfcrniaiii 

riM Draft laTlxMBMtal ScacaaMU/Baaai 

tti« Castrai Vallay Prajact aatf tha Itaca Matar Prajaci akaald ba aadlMtd aa 

foll0«ai 

Fa«a 9L, Saa failf Urtaloa. Is L*77, tka I. I. hMTM* •< laclflMClaa ckaaaad 

tba daalga o( tha aro)*ct froa a coaklaaa carnal aa4 ala«l-laa tlacrllntlaa ayatan 
CO a pTaa»«ri«a« plaallaa aracaa. Tha a*caaa aaacaac* af ika aacaad fazaasapb 
or tha rlakc calMB aa Faa* *1 •haal* ha nalacari hr tha (aUaalas aaataacaai 



'rroa cha taaaialt. mcac allL (lav chraafh tha l.a-alla aalactat aactlaa 
of Fachaca T«aaal aad ha iLftad hy tha Pafhaca Piaplaa PLaac ta tha 
S.j-alia rachaca Taaaal kaacb 1. Ptm tha taaaal. aatar vlll ha caavayad 
tor graTlty chraach a^pallaaa ta tha tatalaal (actlitlaa la laaca Clara 
Coaaty aad tha taa Jaata laaaraalr la Saa laatta C ia a Cy.* 



siacaraiy. 

l>[. tarmartf 1. CoUaaz 
UvlroMaatal SaaclalLat 
Projact hawalOi^aat Iraach 



105 



SOUTH DElIfl UliiKR flfiEOCy 



Octokar (, 1*U 






i?» 



/^^ 



ttr. tob Scbroadar 

D.S luraiu of laeUaUlaa 

2800 Cotc&M* Umj 

too* W-21J7 

SaciaMXta, CA titli 

lai Orait IIS/Ill r* CooT«taaca4 ' 

Oparacloa IgiiMMt (00*) CVT/wr 

D«u Mr. tchroiJOTi 

PuTiuuc CO tba Bottc* 4*t«4 lapta^xr II, ItlJ, <M 
•r« lutialcclna VTlcccs coaant* on babalf ot tha South Dalta 
Watar A^ancy to axpraaa our coocan orar tha lack of analyala 
of poaaibla datrl^mtal affacta in tba aouthan OalCa uiwW w 

by Incraaaad total Dalta 41*«TalaBa aa a raault of Joint 3 

o^aratlooa untfar tha COA. ^ 

Tha UMA faala that tba III ahaul« corroctlj and ala^iiatalr ^ 
daplct tba potantlal impact of tha CQA oo tha loath Dalta, (n 

particularly in ralatloB to tha potaodal for woraanlac 
tha aavara loaa of a(rlcultaral pua^ draft la acaa louth 
Dalta cbannala aucb aa occurrad during 191}. Thla vlll not 
ba a problaa If tha DUI and tha luraau JolotlT arorlda tha 
■ItliatlTO aaaauraa propoaad lo tha Sapt. 198) lattar of 
Intant bataaao tba DWl and inu. » o »a»ar, thaaa aaaasraa 
ara not Ixicludad In tha coordlnatad oparatloB aa iMa dooo 
for tba Sulaun Harth par pa«a 8-2. Tba abaanca of louth 
Dalta atandarda In cba CXM and In Dacialoo 1«IS la ackiia<rlo4(o4 
on paga «7. and tba naad for ■ItlfatlT* faellltlaa la dlacuaao4 
on paia 17. BoaaTar, aliaahara In tha III It la allagad 
that Dalta aaricultura la fully protactad by tba CO* ataadordo, 
a. a., pata S5 atataa that tha CO* *Srould bava ao advaraa 
aflacta on Dalta afrlcultura*. Tbla atataaaot dlaraurda 
tha potaatlal tmdar tha 00* for iacraaaaa la coafclAoa CVT-fUV 
axporta In althar tha aa^nltuda or duration of coab ln ad 
cvr-m paah azyort tataa. aa dlacuaaod, for axa^la, oa 
pac* l->- 

Tba potaatlal l^ct ot tba CO* oa tba aauth Dalta la 
aoc aaatloaad la tha dlacaaaloa aa pafo I-), ot \ m i n 



[ii 



Octokar (. Itl> 

r*«o a 

mtlutloa Naaauraa ai Cuwlatlva la^acta on pa(a I- '•or 
S iSli l-iroTaa a "poaalbla adraraa ta^act"- at tha kottoa 
" plli JJ. « Li Tablal. On .a,a 17 undar ljltl|atl»a 
Saama. ii la atatad that -tahlbit * .t«>d*tda H tha Propoaad 
i«lS ara altUatloa tha^alvaa for tha projacta". Tbla 
UclaarlT not irua In tha .outb Dalta. h.a lapact of tha 
„ol."a Ld tha pot«.tlal Incra—ntal I— act undar tha CO* 
Jwid bl Stlsatad aa dlacuaaad oo pa,. I>. but tha CO* 
■akaa aa auch provlalon. 

Tama vary tnalj. 



wiLsoa. ■08UTT I miTUoa 



DU/r« 




I 
I 
I 




EH 

wCAvcnviLLC. CAijFonMiA aooss 

BOABO OP SUPERVISORS 

r a Diiia A* (till 



Ei 



H«.Mft«r IS. ItfS 



•ur«au •« ft*<l«*«lia*i 

^•00 C«t(«9« My. Rom U-21JT 




0*ar •k' . Sc*ir*«4»r: 



Pla«M find •nclvMd « C«*y cf !»>• C> — W>t« r« IM Orcft l«*lr«MM/(«l Iw«cl 
• f lh« FaMral CMttr»l V«lt»v fr«i«cl Mtf th« C«ll(wai« lt«(* M«t*r Wr^|^€^. 



TRINITT COUMfT MMO » tUPfMlMM 



eoiQimt u turr ■■TiioviavTAL ikvact sTiTtmrr/ttroaT 
stniam» ti tiiiitt coovtt iOii> or suriifisois 

COOUII*TI» 0»»ATIOH AOtlBUKT 

1. «tTIB»TIVI 1 - TM »ro»*a«« aetloa rala«s ooacaraa ovar vatar 
ka«#arataraa la kka Trlalty Rlvar tfariaf aritlaal vatar yaara. ■• 
akara tkak aaaaara aa« •ob14 aat Ilka ta aaa aay aaaitlaaal 
lataaka —tr ta tka iapraaaad flakarr of our rlvar. Sybataatlal 
atata a»4 fatfaral fnaaa ara fealaf aMat to raatora thla loat 
fflaharr- Thla affart la havlaf a yoaltlva affaot raoaatlr aaa aa 
•••1« aat llha ta a«« aar aaaitlaaal bariaa ta thla raoovarjr 
arrark. Tka faat that thla l»»aat la llhair ta oaaur vary 
lafra^aaatlr la at aoaa aoafart aa loaf aa it aoaa aat ooawr 
4arla« a p*ri*4 mtfm aatlalMtaa riah pr*auatloa la alraa^v aoaa. 
Wa aoal« haM tiMt aaa af CfV aatar far «alta aallalty eoatrel 
4arlBfl thaaa Mrlatfa aaa ba ta*Mr*' altb raaaoaabla Juasaaaat 
ra#ar4lB9 raaaaraa iaM*ta aMa •thar altaraativaa ara avallabla 
far aaa. 

■a alaa bava aaaaaraa far •»r laka raaraatloaal layaat tfurla* 
Mrla4a af «raa tfaaa. Tha a««a« aaaaoBla airaaa ta our oaaatr. 
tfayaa^aat ta a larfa aa«raa apaa raaraatlaaal aatarprlaaa, la 
dirrtaalt ta baar. Tlaltar «ar aaa aarlaf thaaa Mrleaa «ra» 
4raaatlaallr aa« taha a laaf tlaa far raaavary. for aaaayla tba 
lata mt *laltar Or aaa. aa a raaalt af tha l»TT araufbt Mrto4 aa 
Trlaltr taka, baa aat r«t rlaaa ta tha lt79 laval a«aa thaaflb alaa 
raara hava »aat. Thla baat ha** ayallaal la»aot la tfirriaalt far 
aar fraflla raaraatlaaal bualaaaaaa ta tolarata. burla« thaaa 

aritlaal raara tfraa aam af tba laka abaaia ba adjuata* aa Miah aa 
^•aalbla ta ra4«aa tbla laMat. 

Oa Mta M - Trlaitv Urar Vlah riaaa. 

■a «a aat ballaaa It la avpra»rlata ta waa tha ert«laal 120.900 
•ara-raat aialaiM la tba a^ratlaaa plaa far tha varloa 2020 aa« 
baraaO. Tba Baaratarlal iaalalaa far 240,000 aoraal yaara. 
SaO.OOO «rv raara, aaO 140,000 la arltlaallr Orr raara ablab la a 
t> raar aararlaaatal M'laO alll auraly aavar ba allevaO to flo 
baah ta tba, kaoaa ta ba Irraaraaalbla, laval of 120.900 
aara-raak. Ta avaa laplr a raaaaklaa ta that laval la traaaaaoua 
ka aal Tba plaa ahaalO aaa tha ailatlat laatraaa flo* lavala aaO 
aaaapt aajp aOJaataaaka that alfbt oaaar latar, 'ba khar ao ar 
Oaaa*. aa a ra^alraaaat far fakara aaaaOaaat ta tba plaa. Oa 
atraa«lr ar*a kbak all rafaraaaa ta tha orlflaal lafllalatlva 
aatbarlaatlaa far a alalava af 120.900 aara-faak la all raara ba 
atrlakaa fraa tbla Oaaaiwat «aa ta tba karrlbla laaaat It haa 
aattaaa. Oafaraaaa ahaalO ba aaOa ta tba Oaaratarlal Oaalaloa 
ablah rataaO thaaa flaaa. Iraa tbla laval baa aat rat baaa 
OataraiaaO ka ba aOa^aaka. 



106 



im 



Th« MB 

•i 1 1 1 oa 

th« S««r 

Sccratar 

««ua« 

tb« bat 

Trlaitr 

riakarr 

yaar n 

dtaeaatr< 

loaf 

lava 

la yrga 

raaova 

Trlallr 

Saeratar. 

tbat Mr 



lal DaalaloB. 



tba 

abary 
Itvar Ti 
»o»yla' 
atorakl 
ata tb 
■«a 9l 



■pairaa aaanal flava voIm— a abova Laaiataa la 1.S# 
raat aa« tba aaaval aivaralaa trom tba praiaat lat* 
avara««« 1.14 ■lillea aara-faat yrier to tba raaabt 
Tba IBM** •t tbat dlvaralsa *aa tba aajar 
«aellaa af tba aaadroaaiM riabarv batb at 
tba rlvar bala*. iaaaak afferta kr tba 
bava abam alfairiaaak iavravaaaat at tba 

prograa to rabailtf tbia laat riabary aill 

l*»«rtaaea of tbaaa laaraaaatf tlmtm. To baili • 

kbat aavialaaa a r«4uattaa ta tboao karrlbla 



tfraa 

aak 

tlea 



tbat tba C*er«laata« Oparaileaa Atraaaaat ba aBaa4oi ta 

rafaraaea ta tba 3020 aaa bar*a« laval af flaa la tba 

ISO. SO0 aara-raat aa4 la ika M««« aubatltata tba 

lal •aolalaa af ItOI oatf Ita affaat aa tba Cft vla>« tmr 



MItXSAft MILLSA^ « TMOMPSOM 



M^ 


t:--^'^ 


.'.J« 


.uJiS 


TT . 


>• -^ 


n 


A^ 


1 




— , 


1 
1 


an*n 


t2b" ' 



He. Bob 8cbco*d«c 
Bucobu of RaclbBbtioA 
2<00 Cottaqa My 
SbcibMoto. Calif. >S«3S 

R«i IIB/III O* OOfc 

Da«r Ht. Schrocdar* 

Tba follo«iA9 rri—inf aza aada o« babal^of tba 
Tolo-laaoca Kotor Dlacclct lAlch lloa iM ToloXouaty* 
CallfocDla. and la part of tba aacvica araa of tba 
Tahaaa-Colaaa canal. Tolfr-SajMra Hator Dlatclct eoaprla*a 
21, too acraa aod baa a potaatlal of aarvlaq appcemlaataly 
24,500 acEoa. Ha bava aavoral cblaf coooarDa la taqazd to 
tba ilft/lli. ricat. wo aca eoAcacaad tbat tba U.t. adbata 
to tba pcovlaloaa of tba CalKorala Watarahad Vcotaotlott 
Statutaa <VP1) (taa attacbaaat hacate). Tba III lAdlcataa 
a dlaraqacd tor tba MM. Sacockd, tba propoaad pcofcaa foe 
coatcactUq with tba Itato of Califorala for tba aala of 
iBtaclB wator to tba SMT aaaca data fot tba nataf 
ca^nlcaBaata of aoctbaca Califorala «blch la far bale* 
tbalc Qltlaata taqalcaaanta. Tblrd, m axa ooaoacaad tbat 
tba III accazataly pcaaaat tba facta, nblsb U doaa aot 
almya do. 

Callfocala Matacabad trotactloa Itatataa 

OBdoK 'luaaaxy* yoa atata tbat *tba prajaota aia a»t 
to ba oparatad to Moat pcadatarmlAad ylalda, but ratbac to 
ficat Baat tba naada In tba araaa of otlgln^ Including tbf 



?¥m 



_ tloli 

watar quality atandacda . '. T*". Tnai 

Id la in accordanca vltb pcavallli 



FTa 



good 

atatoBoat and la in accordanca vltb pcavalllog lav and 
court daciaioaa. Dafortoaatalyf tba propoaad COA doaa aot 
adbara to tba lav la tbat raopact. Paragcapb 10(b)(2) (11) 
atataa tbat *tba 0.1. vlll la^eaa daflcloaclaa on watar 
purcbaaad by tba atata U a mMonrnt coaalataat vltb bhiblt 
I.' bblblt *l* pcovldaa uadar parafrapb Kb) aa followai 

'la any y«u tbat tba Caetcaetlaf OCflcac dataralaaa 



tbaca la a abart*ga la tba qjaaatlty of watar avallabla 
to ogatoaara of tba Dnltad Itataa fro« tba cw, tba 
Cootraetlni Offlcar will appottloa avallabla vator 
mmooq tba wtttac aaara capabla of racalvlng watar froa 
tba aaaa CVT faeilltlaa by radnolnq dalivarloa to all 
auch watar aaara by tba aa«a parcantaqa > ualaaa ba la 
protalbltad by asiatUf coatracka, CW autbociutlaiu 
or ba datarmljMa tbat aoaa etbar aatbod of 
apportloaBaat la raqvlrad to pravaat aadaa bardablp. 
In tba avant radocad dallvarlaa ara nacaaaary^ tba 
watar aappllaa for botb aanlclpal and indaatrlal *»•» 
and agricultural um* aball ba radac«d by tba aaaa 
parcaatng* far aacb contractor." 

kll a«tar aaara of tba CW, Inclodlag tba IMP oadar 
tba propoaad ooatraot for Intarla watar, will ba cat back 
durlnf a drought by tba aaaa parcaotaga ragardlaaa of 
wbatbar or not any auch oaar or aaara ara in a vatacabad of 
origin, k pariod of drought la not only a vary critical 
tlaa for aaara, but la tba prociaa tiaa wban aaara in aa 
araa of ocigin would naad aoat to raly on tbalr priority of 
aaa uodar lactioaa 114C0-3 California Watat Coda. If tbla 
proviaion of tba COik bacoaaa lav, it will conatituta a 
daolaratloa of intaat on tba part of Coograaa which will 
taka pracadaa o a ovar California watar lav. Hoald it aaraly 
■odify tba CallCorBla atatutaa, or coaplotaly nullify tbca? 
la aay avast it woald raaalt in litigatioa. 

If anyoaa doubta v^t poaition tba Buraau of 
laclaaatioa would taka in tbla, ona naad only rofar to 
tbalr briafa and argunaata in tba caaa of louth Oalta Hatar 
Agancy, at al. va. D.I. now bafora tba D.I. Diatrict Court, 
laatarn Olatriot of California. Id that caaa tba 0.1. 
coBtanda tbat tbay cannot ba auad bacauaa tbay naad aot 
eonply vltb California watar lav, apoclflcally tba 
watarabad protaction atatutaa. Tba ftb Circuit Court of 
Appaala in aa attanalva vrittaa opUioo Cllad 7/3</kS bald 
•pacificnlly that tba luraau of Kaclanatloa vaa bound by 
tba watarabad protaction atatutaa. Ondar tba COA aa 
propoaad nortbara California aaara, including tboaa in tba 
dalta, would loaa tbat protaction. Tbara la uttarly no 
juatiflcatioo for thla. Paragraph Kb) of Bxhiblt *■* 
ahould in at and apaoiflcally provida tbat a cloar 
dletibctlon ba drawn batwaan watarabad naara and 
non-watarabad onara aa two aaparata claaaaa of unara, and 



107 



pt«*«cv« tka pctAclty is lu* f«K t*»«< la a wataxalMd. 

Thtt profKMal to coBtcact foe latatla avtac (or tba PV 
la a pcopac aciaouaaaot aa loef aa tbaca la a rlQbt to 
racall tba watac wbaa aaadad la a *«totab*d of oclgia. 
Paragraph 10(ti)U)(l), provldaa for tbla. Tttara ara, 
bowavar. ioaufflclaot aafagaacda (oc tba cacall vlthlo a 
raaaoaabla parlod of tlaa. Sactioaa il4<0-3 of Callfocala 
Natar Coda aca fac aora flea aboat aacb piotactleo tbaa la 
tba propoaad COA. Tbaca abould ba laaquaqa problbltlag tlM 
conatructloo of aitaaalTa facllltlaa for tba uaa of aacb 
watar aa tboaa facllltlaa aiat avaatuallf ba paid (or* aad 
that can oaly ba dooa by aalaa of tvatar . Ifbao tba watar la 
trltbdraan tha locoaa atofM. Tbay thaa Lava aoaatbloq Ilka 
aquattac'a rlgbtal Tbaia aboaid ba claac guldalloaa for 
tbla ratbar than tba va^oa and btlaf laa^uaga davotad ta 
It. If tba propoaad CO* la aaactad. It vlll ba tba 
antarla^ wad^a and tba fltat bit of fadatal laflalatloa 
(daclaiatloo of fadaral latant) to aodlfy tba cooaty of 
origin and watarabad pcotactioa atatutaa of tba Itata of 
Callfocala. Ttala la avaa aora l^wctaat atea «a coaaldac 
tba aaat polat. 

Watai Oaa Pata for tba Taba»a-Coluaa CaaaA 

Tba TacbBlcal Kaport of Rarcb, 1914 oa "Dataralaatloa 
of Annual Vatar Suppllaa for CVf aod HIV', la aiaply 
Inaccucata la caqacd to tba Tolo-taaora Vatac Dlatrlct aod 
tba Tabaaa-Coluaa canal la gaaacal . la Tabla 3 (paga 7 of 
tba Raport) tba Sacraaaato Canala Qalt of tba CVF pcovidaa 
for dallvary by 2030 of only 430,300 acca-faat aaiwallr **4 
Indlcataa a 1*10 daaanil of oaly 12S,000 acca-faat. 

Tba Tabasa-Coluaa caoal aaa aotboclaad aod coaatroctad 
to aarva a lacga pact of tba Kaccaaaato Vallay la Tabaaat 
Glann, aod Coluaa couatlaa. ba a caault of laglalatlm &■ 
12/10 tbla vaa aitaadad to Inclada Doaalgaa Vatac Dlatrlot 
and Tolo-Saaoca Batac Dlatrlct la Tolo couatlaa. Tba 
Bucaau of Kaclaaatloa bad pcavloaaly ca«acd*d tbaaa 
dlatclcta aa balng In tba TVbaaa-Coloaa aacTloa acaa* aad 
tbao in 1*77 obtaload a lagal opinloa to tba coatcacy. Tba 
laglalatloa cacad tbla aad ralaatatad tba aalatlag Daaalfaa 
Watar Dlatrlct and Coluaa aatac Dlatclet caattacta fac 
laada la Tolo Couaty. 

la l»5a tba aacaaa aX lanlaMliaa pobllabad Ita drat 



faaalblllty capoct foe tba Tolo-laaoca Matac Dlatrlct. Tba 
caport propoaad to dlatclbuta 40,000 acra-faat froa tba 
Sacraaaato llvac tbrougb a ccoaa-caaal fcoa tba ftaccaaanto 
tlTar. Subaaquaotly (19C3) tba dlatrlct «aa laiwctuaad by 
tba Bacaau of laclaaatloa aad dlatclcta aoutb of tba 
Tolo-laaora Vatac Dlatrlct to abaadoa Ita plana and aupport 
laglalatloa for tba anlargaaant of tba lovac tbcaa caacbaa 
of tba Tahiaa rnliiia canal auch tbat watar could ba 
dallvarad to aoutbaca Tolo County and Solano County. Tba 
dlatrlct accadad and tba laglalatloa waa paaaad In 1*(7. 
Tba aolargad canal waa coaplatad la 1901 at a coat of about 
ISO alllloa dollata. 

Tba tacaaa of ftaclaaatloa pcapacad a wclttan capoct oa 
tbalc watac aackatlng pcogcaa foe tba Tabaaa-Coluaa canal 
on Octobar 27, 1977, a copy of wblcb la attacbad bacato. 
Tbcoagb laach ■ (aad of tba caaal) tba Buraau of 
laclaaatloa coatcactad to aall 312,700 acra-faat annually, 
aad caco9Blsad a potaatlal additional daaaad of 2C1,900 
acca-faat, or a total of S74.(S0 acra-faat. In addition. 
It aatlaatad an additional 40,000 acca-faat for tba 
Tolo-laaoca Matac Dlatrlct wblcb la now a part of tba 
aacTlca araa. Tbm cuccaot aarvlca araa would tbaa bava a 
'*T*t*^ of C14,<S0 acca-faat animally. Tba propoaad 
waatalda canal would call for an additional 101,000 
acra-faat annually, bringing tba total Tabaaa-Colaaa canal 
daaaad to 722.450 acra-faat. Tbla la In abarp cootcaat to 
tba Tacbnlcal Eaport flguca of 430,3001 In fact, tba 
lattar racognlsaa only 5*1 of tba potaotlal danaad. Tba 
Tacbaloal laport ia aattlag forth a 1*00 daaaad of oaly 
12S,000 acra-faat. waa alalaadlag wfaaa, la fact, aa long 
ago aa 1977 tbaca waa 313,700 acra-faat uadar contract. If 
wa addad tba additional watar ra^uaatad aod aaadad by 
amlatlag dlatrlcta. tba total daaaad would alraady ba la 
asoaaa a< 430,200 acca-faat. 

Tba faaaablllty caport of 19SI for tba Tolo-taaoca 
Watar Dlatrlct gava a total of 21,700 Icdgabla accaa and a 
gcoaa aoraagaof 3<,l<9 acraa, bat tbla waa for landa wltbln 
or adjacaat to tba dlatrlct tbat could and probably would 
ba aarvad by tha Tolo-laaora Hatar Dlatrlct avantually. 
rraaaaably, tbla waa tba caaa with otbar faaalblllty 
raporta. Tbla aatbod of coaputatlon of accaaga aad total 
watac raqulraaaata waa cootlnuad up until April, 19IS. At 
tbat tlaa a lattac waa aaat oat to watar agoaclaa advlolaf 



tbat tbay vara aaklng a aaw aurvay of watar naada. 
Bnclooad waa a auaaacy of tantatlva caco^atatlona of 
ultlaata oaada. Tba lattar. bowavac, atatad, 'Plaaaa nota 
tbat tha cootcactual watac (a9Ulraaant ia baaad upoo tba 
naad foe watar to all Icclgabla accaaga cutrantly locludad 
wltbln tba raapactlya dlatclct'a twundaclaa.' VEaTaquaiFa 
ot Coluaa County Katar Dlatrlct aad Dunalgaa Watac Dlatrlct 



waca cadvcad to aaco, 
IS, 740 acca-faat. 



lolo-laaora Matac Dlatrlct to 



Wm bava, with buraaa of Maclaaatlan aaalataaoa, aada a 

aurvay of all Bucaaa of Baclaaatlon cacocda and 
co^utatloaa of our watar caqulcaaaata and flad tbat wa oaa 
aaally ]uatify ovac SO, 000 acca-faat for aar araa uaiag tba 
Buraau of Kaclaaatloa'a owa data aad crltacla. Tbla la 
probably tcua for all tba otbar dlatrlcta aa wall. Tolo 
Flood Control aad Matac Coaaarvatlon Dlatrlot aad Solaao 
Icrlgatloa Dlatrlct, to tba aouth of Tolo-laaoca Matar 
Dlatrlct, bava oaada of parbap* liS.OOO aora-faat or aora* 
and ara not avaa llatadi 

CXic caaaon foe aantlonlag tbla la that tbla la all 
pact of an ongoing pcocaaa of nagotlatlng tba aala of 
Intada watar to tba IMP. Tbla aala will ba at tba hlgbaat 
poaalbla pdca aa aoat of tbaaa uaaca la tba twf will ba 
ainlclpal aad laduatclal uaara. Our watar raqolraaaota ara 
balng ainlnlsad In tbaaa raporta aad aagotiatloaa In erdac 
to aall aa aacb watac aa poaalbla alaawbara at a blgbar 
prlca. 

An Iroalc dawalopaaat la tbat tba tacaaa a( 

ftoolaaatloa baa fllad an application with tba macs ta 
•ipand tba placa of uaa of CVP watar covacad by atata 
pacalta. In aoctbata Callfocala tba plaoa of usa lo baiaf 
aipandad to tba 1000' laval wbaraaa tba laglalatloa for tba 
CW doaa not glva claac autbodty for oaa abova tba vallay 
floorl Tbla la aaplalnad by tba bucaaa of Raclaaatlon aa 
doing tba thing "onca and for all* catbac than going back 
foe rapaatad patitiooa in tba futara. Mo aucb patltloa baa 
baaa fllad bacatofoca aod tbaa It would aaaa tbat tba 
pcoblaa of rapaatad applloatona la caally aooai latant. Oa 
tba otbac hand, oalng tha araa tbat a dlatrlct can 
coovaalaatly aacva aa a baala foe coatcact nagot latlona, aa 
tba iocaaa of laclaaatloa baa baeatefoca dona, aakaa a 
geaat daal of aanaa. Tbay now ao loogar wiab to do tbla. 



iBGlaaloaa ara aada feea tlaa to tlaa la ^t dlatclcto. 
Ckir dlatrlot would aotlclpata iaclualon appllcatlona for 
about 4,900 aoeaa onca wa go to conteact. Tba Bueaau of 
■•fllhaatloa raooqnlaad tbla la peavioua capoeta. It would 
ba a aarloua datdaaat If a dlatrlct had to aaaad Ita 
contract aacb tlaa it had an loclualoo. To taka tbaaa 
lacloalooa into account dueiog coatcact nagotlatlooa aakaa 
a graat daal aora aooaa tbaa tba aapanalon of placa of uaa 
to tba 1000* laval 1 

Ma tblAk tbat tbara aaoda to ba a blgboc doqcaa of 
conaUtaacy ia tba Baraaa of Aaclaaatton actloaa. and tbat 
tba aoraaa of Baclaaatlon oboald atop juggling tba flgaraa. 

Xa eonclaalon, wa faal tbat a atrongac aod tlra 
racogaitloa of tba Califorala watocahod protactlon lawa 
abould ba locorporatad into tba COA ao aa to pcotoct all 
wataraboda. Tbaaa watarabada alao locluda tba dalta. Aa 
It la, tba propoaad COA aubvarta tboaa atatutaa. Ha alao 
ballava tbat tba Tabaaa-Coluaa canal aacvlca araa ahould ba 
aapaadad to full capacity, including tba ranalalng land la 
Tolo County aad Solano Couaty. and tbat tbalc fall naada 
Bot only ba rooogalsod. but racogalaod aa a flcat priority 
La oaa* 

la vlav of tba cavallar approach alraady takaa by tba 
kiraaa of Baclaaatlon la tba Soutb Dalta Hatarabad Agaacy 
caaa aow paadiag, tbla bit of propoaad laglalatloa can only 
ba ragaedad aa bcaaaa. Tba propoaad COA would ultiaataly 
alialnata tba priority ia uaa of watarabado of origin, 
lAoladiaf tbat of tba dalta. 

vary truly youca. 



' ^S ?? !:](i(u. i^ teg, 



Iola-l< 



Toi" 
« lut.r Ol.tclot 



■l/ai 

eoi loo. vio r.iio, i.e. 

•oo. a..i4. 1111. t, a.c. 
•oa. lug.a. Chmpvl., II. C. 
TatuAA-Col... lf.t.r DB.r. Assn. 
Cuict.l v.ii.r riojMt itat.r JWu. 
IM.Uld. CUMl kmma. 



108 



SlUiO. D«pclv*l of pcioc clqtat to watoc to supply 
watocabod acoa 

In tb« cooattuctloa and opocatloa by tbo dopartaaot of 
any pco]*ct undac tb« piovlaloaa o( ttaia part a watarabod 
or acaa wbacain watar odginataar oc an acaa 1— ■dlataly 
adjacant tbacato wtilcb can cooTaalontly bo auppLlod ultb 
watac tbacafroa, abail not b« dapclvod by tba dapact»ant 
dlcactly oc Indlractly of tba prloc clgbt to all ot tba 
watac taaaooably caquliad to adoqMstaly aapply tbo 
benaficial nooda of tbo watocabod, acoa, ec afty ot tbo 
Inhabltanta ot pcopocty OMioca tbocoln.* 

*statutaa of IftO, Ch. S)3 attooptod to aaand tbla aoetio* 
but tba aaopd—nt waa rajaotod by tbo votaro oa a 
raforaodua vota. 



$114<3. 



iHcbaaya of watoc botwaoo ■atozabodo oc atooa 



Id tba coaatractloo and opocatloo by tbo dopartaoot of 
any pcojoct undoc tbo ptovlaioaa of thla pact, do aaoboDgo 
of tba watac of any mtocabod oc acaa foe tbo wator of any 
otboc votocabod oc acaa Bay bo aada by tba dopactaant 
unlaaa tba watac caqvlroaaota of tba watacabod oc acaa la 
wblcb tbo aicbooga la ooda aca flcat and at all tlaaa aat 
and aatlaflod to tba astont tbat tbo caqnlcoaonta woald 
hava boon aat woca tba aacbanga not oado, ODd oo dgbt to 
tba uaa of watac aball bo galsod oc liMt by coaoott of any 
aucb oacbaoqo. 

sunt. LlBltatleoai Jkppllcatioa 

Tba lloltatlooa pcaaotibod U Soctloa 114H and 114CI 
■ball also apply to any aqoocy of tbo ftato or rodocal 
Govacnaant wfalcb aball tiodactaka tba coostcootloo oc 
oparatloa of tba pcojoct* oc any onlt tbacoof, laclodlaf* 
baaidaa tboaa apoclflcally doscclbod, additional oolta 
wbicb aca conalataot wltb and wtilcb aay ba conatractod* 
■alntalaod. and opocatod aa a pact of tbo pcojoct and is 
turtbocanco of tba oinglo objoet ooata^latod by tblo pact* 



-xtK^n 



"><>.„, 




(\-^-tf,-/ l<. //,v O-'-J-.-l \ 


-.. -_J 


Cm*** 


M<t 










f'"*- 



j£iL. 



(*•'> 



ll>r\ 



I - - - 

t i.foo %ta» 11,0— 

S-7 *c^7oo tsi.isn iliH.ltC 

I it. too - tl SK, 

utmt ill. 1— ^i^i^fja ■z f'i.tso 



1''a 






■ >. 2. 


r.\v> 


'••J? 


/ 1 '. 


aioa 


nr 


i.ri 


2ioa 


HI 


r-.-l 


craft 


l.-i-K. 



Ml fA 






/I-JV. Aa 



109 



THE BAY INSTITUTE 

OF SAN FRANCISCO 



•uraai of tif l—tl— 
2(00 CMUt* "f »-ll>' 



CaUtor»i« 
of (tour 
U31 I IcrMt 
111 1^1 to U-MM* 




^^'i^gr^n 




«i ■»*<» m/1 CQ» cft/i 



iirlniaJ 9IMM ftad ly arltb 

■y oral u^nsu >r»— fJ •( th* piU.lc fcaw !■> M 



TlM p*ltc Mtlca prwrliai tm U* ^iTl«t B 

at C4WCOT4 «M 4aficlMC. Ta ^ ^mamlaAm S 

1 r*c«tvtt4 •• aocic* la tka aall, iaaylta ^h 

M"^iMCi«a kr •• IB (iaU haarta«B •■ eta ^ 

Draft OOA <ar1t tka ^aac na fMva. c» 

(Alaa, 1 hava baaa aa acttva p^rttAi$m». te 
ttaca Hatar Buiwiii C«atrol loar4 haarlafa 
of all klada affaccla« tte tw r«*lla pf^m^t*, 
md ^ mt Om taraaa of ladJi 

UM tv ■■■9 cvr I iiiiiii.) 



k. 41c] 

Sr*«K to ha aat kf avy | 
I ouuaat tkac aaeloaai co^aaca aa^av ). 4 ^rf 
7 ara prop ar *m t« Um <1) 1^11«4 tw^mtm mt 
aatar fraa CTT 1 



m cvr aaacraeta If cka OQA U ^fioiaj 
riaaaa Mta wrliooi bUUt «m tkm Scxlyad Baaa 
ta ^ focaai ai^MaCa. 



10 



tu •■ eta isaft failiiMaaril l^mt ttataMac/layarc 
COttODUXD OnKAnOR AflUMVr 
Caacral Vall«y rvejact/ttata Itaur Prajact 19U 

«iw Mraeuv, tta tay taaticau af tm Pr« 



af tta BU/I axai 




miiJB T. ana 




@ 



■ca of U. T. Davaraa oa Dcafc lU/l fa* 004 



loata^uata avalMClaa/Alacaaalaa o< 1^ Lala Brala. *-*^-^*-t 
ttlcaraaclvaa avallabla If fraaaac aaarck fac 1 
•olac taaa < 




Coaaoat i»»ltao to i M«* **• MlaoB «■' ou-lfari kaaa aaaaal 
dollar ratara oatTaaCaai MS* 'O. aal^M laaaal walaaa* all 
ififlni staaltaatf eoMlarf im iilly at tarf Uaff Maanlaa 
Db. m 4aUaa wlm niiilio*. 

4 aav aaarea la* 4allar valaaa oa airlfad taaa. aalaaa aaii 
acaaltaai flataxlaa ta aw avaUakla. Ic iai 

Tta tcomamU falaa mt ICrijai Jaao. Iloro— aaaatalU . 
Cblnoofc tolaoa. Oacorbw^taa ftaartacta. mU ttaaltaa^ 
Trowt. talao Mlrdaaft. »< tta tacr— ta aai t4ii 
Joa^aia tl^ar iT*t— 1 

A rofo r t ta tta Callfonla luirraMr af Plak m< 
Coaa by tarar taiaartii lao., Davla C4. 
^iaitriaiin riatariaa troKk Italalaliatlia "nm 

ta. aS-0). 1M5) 

4. ta rafaraaaa ta aa 41icaa*lM af tta • 14as/talU tlm tMtm 
aa ■■ affUlaUy app r aa^ tataral^Cate wmtaK faallCf if <■■!■ 
v1j« ^tar tactlaa »3 (•> af tta Claaa taUr 4m (IS OK 1M4). 



7. ta llatla« m aMIlaaa 9t mm*mmn-mi 1 
Urn JBa<aia f alia? oarrlaa 1 
Cft aa^fllaa la tcrj amd crttlaal yioaa. 




■li^aetfalAy aataUUrf. 

WlUlMi T. D««acaa 

atlva Dlraetoc, tar laatltau of 
Sao rrtlato. SOtO ParaAlaa Tltarai 

UtlO 



at^taa af CTT/Wr ralatad l^acta «• fUtarlaa. 



Co^wat am»H»9 ta i fa^a 24-25t m«> ^' <witorlyin< ■■■i^cloaa; 
M^ *>*, aa^laMa4 I 1 111 tt P»m» iO-H. iiiiaaiiiHag 

D 144S/talta PUa j- — ^—'- taaad oa SBI at "wlctaac 
projaeto' Laval of Tf; ya^ 30, ao aaatlaa of toxleai 
f*t^ M, CVr/nV a^ratioaa "oaa of aaay facta** afl- 
actla« fla4..."| p^tt M, ni fallura aa«ataa all 
W Tyoaad taaaflta af Pro»o*aJ 4ctlfla; ta4* M. 
•taca 14A5/talta Plaa taaai oa "Srlctaut FT«)«ce" UvaU 
of pretactloa for Btrl^Ad taaa. l.a. UI af 7* aalta, 
coocaytMallr ta 4ctloa altaraatlva ahaaU a^aata ta 
D 1443/talta riaai pa«a 41, rrwmaaacaa la Cft 
aarvlca araa ataaH laclata taalca aafca^fan 4rala aaaCa* 
•ffacta (larraaaa/tacraaaa) aa atrt^d taaa aiwi«al. 



2. rallara t* iaacrlta fiataxy protaccua ataatarta af D 1415. ■ 
md attar bb]o* ttaaata of I lUS/Balia flm, aa Yrrr aa 
"vlttaat prajaat* LavaU af flak ' ' 1 



tllaa ta i PM* ^2. pa^ 14. md t 



1 othar taacrlytlaaa 



itura af ICata Uatar taaovrcaa Coatrol taar^'a 
■atar rl^bta (D 14t3) aad aatar ^ualltr (Uata* Qoalitr 
CaatTol riaa fa* tta talta «a4 In I aw tarak — "Dalta tlm'). 

ta c laa i aa af ^ kiaca*^ af tta eoacoaitaat 41i^piaiaaca of 
2 aUllaa acraa a( Caacral TalUr aatlaata vltk aarafcllahaaar 
af CVP aad ■». 



at ta^iUi 
of oaij 



to i aacaaalty to c oaaltar raaa<ial altaraatlvaa 



«ia« CTT aatar aaa ralaaaarf, la affaet. ta PV, 
for corractiat alarlaaaad amd implama»4 lapacta af 
err aa aatlaaia la aarvlea araa, aiparlillr taccaaaal 
Uaar Valtay. 

l^acta af CTT iaaaTita< aufcaarfaea ratiaa flaaa aa 
pTlvata md pakUc aacLaada of taa frrarila Vallar. a 
fiMC t iaa af at^plylm^ CTT aatax to aarrlca araaa. 



I aa Draft lU/l fac 004 of CVT/aMT 



SmPCD BASS MOO 
WVCAM 




BESeSlB 



a* ttrlva* 9mm lataa (m> 4U aaaralaw aaU altk rl«a* fUta. 
Mi aatar ^laia l aaa af tta Uria n*lia fnjMU (CTT, IW), fraa 
1»» ca lt7«. Tta faUara tta a^Ma atava. fac tta tm** 1977-lMS. 
taa v*tlfia4 kUla^lata md aagtaiira ataea 1*77. Tta Uaaat UX 
aiaca lt» (*.S mlta) aaa raa«*4a4 U IM5. 4aarlta avaraca aa4 ataaa 
aiaiae* aaaaal rwaff flaa* alaaa lff7l, 4aa»lta ftah rretacclaa aaatrala 
U aa af>*aaa< fa4aral-«taca plaa (> l44}/talu PLaa) ctat ealU for m 
aaaaal til af 7« aalta, aai iaaylta aaay l^rwaaaata tta paat tacata 
ta tta ^aaUtr af —lilpal Md liliii r rtal aaata 4laitar^a. 

Tta ax af 7« ^ta la aalaalaCaJ ta raflact «tat iiaai af ita yaar 
atTltai ^»»» i fc ia'ii n aaaU ta if aalttar tta fatatal Caatral ValLar 
Projact a* tta Icata tatar PraJaaC tai «aar taaa taUt. Coa^araJ ta 
tkla "SrlttaM prajaet" ataatartf. Cta faiaral-atata flatarUa ax^rta 
••tlaata tta« tta rpara^a akataaaa af y a» g atrlyta taaa (a* tta yaar* 
lfl3-lf«7 aaa 104 lataa aalta. 411 aaek 4ata r«««l*aa araw4 aatar 
rrejMC 4r*«lopaaat vT*KtUaa af tta pmt 40 roora Ctat ar* faarai ta 
aac4 ^ajact frorUta* '*altl«atlaa* aM 't^a^i^^t' taaaflta ta 
offaat aar 4aUtarla«a l^ofta. ta aack It rayraa^ta a kyyaa ara 
of aatar aaucaaaat. (Pot laaapia. tta taf af tta Dl acaU la 120 
wltai tta raaa^lal fLatariaa aai aatar traaafor pr«}*ct taoaa a* 
tta Parlrtaral Caaal. iataatta Vf tta Calif tnrnla •lactaraco la 1M2. 
aaa prajaetai to previta aa aaaaal ni 0I no. Tta akloct (allara 
af tta UI alaca If77 axyoaaa tta aavara atartcoaia«a of auck alaala- 
ayacUa flaaala«.) tatalttai by tta tay laacltata of taa rrMctaea. 



110 



Doo&ld HMltX 

Off ic« wi tW S«cr«tUT 
DcfMrtMoit if lat«Ti«r 
MaahiactM. B.C. MMO 



Dckf S«cr«tMT I 




Ttarf J. 0«&i«, CMwatMH 
CftllfMmi* TrMt. Uc. 

■ ■ Cf — f , Ck. IMM 

11/1 a/is 



^^>r^^' 



I wr**^ M cm«ltwi« t« «»• <MlUtwim tUt* t«M*a S«l««t OHMiiltM «i MA 
Md GflM iiU«U/« (rM l*7t^i, ud «■ vrvMBtlT mi lift m mtar pc«>««» 
lot CMlUmwnit TMvt, lac., * aaier fiihtft— n—iinti— tr«a». Omt •r«a«isaft> 
iam bslima ttet tiM Dn/t ImrlrWMMttJ lapMt Itmt— t/tfrt, CMf«laBt«tf 
OpcntiM AffMMat, Gntni V»11«t Vl«><l/lt»t« Mtar rr«>Mt. Jalf IMS, U 
^eikcUst ia brdroXogiMl. >tMowic, b^ iBvir««MatU ^*lr«i«. TU A«xMaM« 
itemlA aot h« utlMxlaa^ br tt^r«M Mtil tkM« teflclMdM u-* cwrMtatf •■« 
■or* MtlifMtarT sillfati** mmwm w* %d^tmt hf tk« laraM atf aaclMMtlMu 

»ila tlM drkft US prcMat* MalraU «# tlw ihIiim iitil •tttf tt tta if w 
■cat ««rlag !•■ ««t«r r«u>. it «••• ■•« waira* i^icf terlac — ffcl «ftta« y«a*s« 
1W Ayiaawt wmu.lt n*mtm la/lOM t* Sm fTiflifi Bkr by aiii» «•• aiUlM 
•cr« fcflt L> ■■rail rmr%, mmcm vktar pagrtiai caatracta tra 4«v«l«9a« tatiwatt 
CTF Ma svr. Tat tW lapMta a/ tkla ri<ati< flan «■ tka tey aaattfataa tn ami 
vraa aaatlaMtf La tJM draft SU. 

IWra U ■• Mttlfala tt tk« ■!€ baaaf tta «f tiM Agril— •• Cn aatf MV. 

TWaa cvMt i c iaiatc taMtflta BMt to —!§>■< U Aataniadag tka aaawt «f 
Kltiifttiaa. U CVr it &Ua ta aail 1 NkT laii— 11| ta JtfF aatf atka* partlaa •• 
tiM rvaalt e/ tba Mf** Kt a prlca of ISO »•' Acra faat a^ ri*!') tkia 
■■nnu ta S30 aiUiaa ia laaatl rwaai ta OIBU Va kaiiaaa tiMaa ravawMa 
•haaJd »• ai«a ta /«■« aAticatiaa /ac tka cxUtii^ 9C«>«t faciUtlaa i^acta 
oa fiak tmt «lUlL/a. Uaa, part a/ tiM aatar ■■«• arailakia ^ Um *i laaaat 
UMMia a* aaa* it mH ■■€■■— t a/ iaairaaa /lam «a aajac rivara avc* aa tM 
Sm l aaaa l a mt StaMialaaa i*ick kiava toaa atfvaraalT affactatf kf IBM 4iv«rai«M. 

«« m i n t tb« vwlaaa iiiiMi nm a»a af tka O.S. Hak Mtf MUXi/a Sarvlaa 
rccaraiac sltlfatiM. TWaa fcaiwiaatiaaa aaiMrUr «aal ^tk flaaa aa« aatar 
tw nr tl w aa ■■ tka S^nmamf Uvar. aitlw /Ian aa tfta i«arica« Uvtt, waA 
daliwrr af aatar ta vliaiL/a rafa«it. fcaair ar . aa ttaafaa altb tkalr aimimm 
Haa fi fn — iwi U laaa far tba AmtIcu Uvaci 1T50 cfa Octatar 13-OacMMr U| 
USD eft Janaarr l-Jmm 30i KX) c/» Jaly UOctakar U. u aaiaM^J at tiM — atfc 
■f tha tecclcaa livar. lftU« tkaaa /law l«v«l« aar »a ■aptntiata far a criticallr 
*rj raar aacft aa IfTT. flaa raleaaaa tariag aaAaratalf Arr ma aacaai aatar yaara 
Uaaia to eaaaiAaraklT fraatar, capaciallr «ariat BHaar aaa«lM. 

to tolicaa taat alat— fiaaa «iiria| aaaaratatv Mrr •«« aaraat r^n aaMd4 M 
St laaat 3000 cfa all j»%x. Tkar* ij a grvat iacraaaa ia atraaa aaytk Mri aattatf 
pcriavtcr at 3000 ctfa /laaa atMa caaa«ra« wltk a fiav af IJOO cfa. It^iaa «aaa 
br Daa KcIIt aa« Aaaaclataa faMd ttot tUa 900 cfa iat^wMtU flaa raiaa* 
K*«ra«* atraaa toptk by • iackaa ta aaat atraaa aactiaaa, fraaUf iacr«aaiag 
■ f — ' M uri raarlai haMlat far iil^a ^ aiaaltoa* 



Aaaricaa tdwn flaaa avarafa S.T aililaa a«r« faat, aa a*ara«« flaa af IMO afa. 
tl !■ aparatlaaally faaaikia fa* tka laraaa ta acUava tAaaa JDOO c/a flaaa by 
a aariarata <*M«t ia a^aratiaaa at Paiaaa Laka. rateci^ «traaa floaa ia Mar- 
Jaly md iacraaai^ flaM terij^ A^aat totaakii. TMa rau. i*i<* kaa toaa 
falttivalr ary. tearlcaa Uvar flaaa a*«raffa« akaat SKM eft ia itor-Jiay, latf 
•ara ^togad ta UOO cfa la Aacmat-Octaba*. 

Aa part a# Um IftkaaMt, MM ibaali aiiify tka praaaat aatar iatakaa at Palaaa 
l«k« aa tkat aatar ralaaaaa aay km aaka fraa taayar aatf caales aatar atrata 
iariag ei^Mr •■« fail aaalto. ttatfiaa «aM by mM fiad tbat aatar toirarataraa 
r«a«k avar TO 4aeraaa P *mtm ■—■*. aaaaarad at Matt Ava.. aba«t 10 ailaa 
AaMctraaa faaa Um daiu ttia ia hl«biy tfatriaaatal ta aalaaa md ata*lbaa4 
^■falatiaaa, aa tbaa* bi«b aatar taaparataraa craata atraaa aad lawarad frawth 
rataa ia jOTanila* af tbaai apaciaa. tUla ataalkaad apav ia tto Aaaricaa. 
vary ttm af tkair prb » «»y aarriva t« bacaaa a««lta tocaato W tka aatar taapar- 
ataraa, lilaia raaa ara alaa affaatad mm ^»lta abicb raaaia la tb* rivar tfariaf 
a^Bar «a aa« aarviva aall. Ili«h aatar taaparalaraa favar aa^aaafi* abich 
caa^ata aitb md prateta ^aa yaaac iilaia aari at«albaa«. 

Tba Acraaaaa« bkaaH alaa oaaait tba iaraaa ta prvvLda (raatar f^^ia« far 
CbltoM MatAary, aa battla Craab. i*lcb aili(ataa tmr Skuta Dm aa tka ticfMMt 
Uvar. md M tabac Batckary, aa tka laafJcaa llTar. CalaaM totckary aaada mm 
isaaabaaart af at laart il.t ailliaa ta raatar* it* pradactiaa t^ • lufar «v«i*- 
it«r« ta iaaraaa* tka pradactivity mi tkia abaalata facility. UabM batckary 
rtba ir ** aaMiAat larger ai^aaAltaraa ta fal/Ul tka ioiat Stata.4» aspaMlaa 
piaA. I tfraftab lafialatiaa. aaacta« by tka ttata ta«ialat«r« ia 1«T«. ahicft 
y i ti H t* tMO.OOO far plMalbg tkia f la^Jto bracTM. 

Ika * m M— I mnntt larlab* ki^ar /lava aa tka Triaity Uvar, aa m lii 

by tka «LS. M* aa« biUlifa Sarviaa. t* raatara ita aalaaa aad at**lkaa4 
fiakariaa. ■«*• Ttiaity Mb, capacity 2.3 aUllM acra faat, toa ra«aca« 
Trii^ty bivar flam at tba tos ait* fraa •■ avasafa af l.M aiUiaa acra fMt 
ib lM«-lvn ta a un it flaa ralaaaa mi aaly MS.OOO Af lly.CW Mta) 

4a aaarac* af aa* ■illiaa Af ia traaaparta« ta MiakaytaM iaaarvalr aa Claar 
Craab. U tka I* rr — aa l i Uvar baaia. At praaaat. alaaat all tbaaa flaaa ara 
• I" Hi* Uractly ta Baatoiah ptiii i biwai aa tka tacraMata'Uvar. ratbar tbaa 
kaiat allaaatf «a flaw iaatraw aa a*ar C»aak. flaa ralaaMa aa a*ar Craak at 
■■kAbkaytaaa arai aara cfa ! ■■ t ipltobii, witk flaaa raiaa« ta JO cf • ia Octator. 
UO cf a U II r"W * i wik* l , 90 cf • ia JbMary-PaftrMry, m4 10 cf a U Harck-Jtoy. 

■a aapgaat tkat tka 33 alia* af Claar Oraab tolaa miakrytavi caaia m* af tka 
■aat iapartaat i|ii*l n mad raarlag tfitotarlaa af tto SxrMaata U*ar aitk flaw 
ralaaaaa af abaat X)0 cf* yaar ara^a. SM racafmiaaa tkit aab kaa raia*« flaa 
ralaaaaa Awiag tka aalaaa apaaiUat parlatf. Uikar flaaa aa • yaar arawia baaia 
ara aacaaaary ta allaa Oaar Oraak ta bacoaa • aa>r ata*ltoa4 rrari^ area. 
Tkia fr *p m < flaw ralaaaa af SOO cf ■ Mawta ta 4».000 Af , Itaa tbaa kalf af 
■ M aaparta fraa tka Trtaity baaia. bkila tkia pragrM aaaU rateca bHiipaa*! 
kaaafita m% batwlcb, va 4aabt tkat it aiaalA to graatly totriwatal. 

Claar Craab baa babitat pvtaatial far aappartiag larpa fwu «f Aiaaab aalato 
amd ataaltoaA. Ita it l aia nai. *v*a aitb praaaat law flaw, aiaibira* 1.013 a«<ata 
ia Itn.tOfO data) Wtk iacr*«aa« flaaa. it va«l« a«par« Mck graatar rwa at 
b iMar aaat t* MB tkaa totckary p f ba a tiaa. UatrvM flaa at«Uaa aaa« ta 
ka iiiiiMla*, aa a*ar Oaafc'a ckaaaal aay to larga 1 1 1 ^l ta aaataia rraa graatv 
tlmm, crtotiaf aa Artificial* apawiaf ckaaaal m a aataral atraM at aa 
M»lt^ Mat. livplM aalaaa latf bttolbaab fry fraa CalwMa totckary caall 



0* plaatatf ia Claar Crmmk ta tafca atfvaa«a«a af tto iacr*aaa4 raarlag araa aai 
ta aatabliab aatwally rapca«aala« papwlatiaaa. 

1k« A4t abaaia alaa caataia a aaaaittaaat by SB to laaaHtol aaw fiak 

ladbara ar atkar aadi/icatiaaa at Aatf Uirff «itorbiaa Ma. aa i 

Uvar. TU* daa. lAlck «i««rta aatar lata MM'a Tal 

tU^Mi-r toatrwctlv* ta aalaaa md attalkaatf papwlatiaaa. tocaato af I 

flak ladMia, it graatly raaacaa aalaaa aab ataalkaab ipaalag aAfsatiaa akaaa 

tto Ma lata tka to*t apaaaiag araaa af tto rivar. 

Tkia caa to raadUy aaaa ia DfO ataiiaa at ulaaa apaiMii^ papwlatiaaa. la IfT], 
DfC aatiaataa tkat 101. 0«3 aMlt ck4aaib aalaaa apaaaM abav* tka Aivaralaa Ma 
•M aaly ll.fX) apiMii AawMtraaa aa tka SacraaaatbUvar to aaar Tafcaaa. la 

caatraat, ia IMO, M,XX> ctilaaaba akwto tto Mvaraiaa 4m. akUa U.OOO 

ftawMaa M tto iicr— aat* MMatrvM ta TakMa. TkU Mta laUcataa ttot tka 
divwralM aam black* Mrkapa M pcrcaat af tba aalWM na fraa atiliai^ tka 
•traaa araa akwva tto Alvaraiaa. Tkia kaa pratoaiy baaa tba aajar facta* ia tM 
graat rabactiaa ia tacraaaata Uvar aalaaa raaa la rac^ ya^r*. •• tpaMlag 
mad raariag babitat U aacb aar* aarglaal ^Ima Had n^t UvwralM «m aM 
wtaa taaparataraa ara caaaiMrabiy aarwar. It kaa alaa MciaatM tka rtaalbaatf 
naa fraa a batal af ahaat 10.000 apaaaara ia IMS to vary toaU lavala at priiM< 

USB facilitiM to tka appar jacraaMt* Uvar aaat to aaiifJM 1 

ciMM praviaaaly plaatifal aalaM m4 ataalkaM racaa ta I 

poiat mi ttoir kacMlag laiiagarM ar tkraataaM apacUa. far iaataaca, tka kiatarla 

raca ^ ataalkaab Mick aigratM lata tto appar tacraaaata bariag lata apriaf- 

«arly ■— ir aaat** 1* alaaat aatiact. Tka raaa Mriag tkaaa aiitli praatotly 

Lnaalat ai aaly abaat JDO flak, aawy af Mick My to raaiMwt raiakM trawt. 

to Mtckary aitigatiaa a* atkar MaagMaat activltlaa tova k*M aaa4 ta ptoaarra 

tkia iapartaat raaa af aalaaalM, Mick U cstiact U atkar tacraaaata Uvar 

araiaagaa. Mtckary prapagatiaa af ttoaa fiak la aatoaaary m tkat tkay Mf kb 

raiwtraMcatf U atraawi tkriagbawt tka tocraaaata Vallay. 

IM il^f Uvaraiaa Ma alaa ia tto priacipal caaM af tto raMcal raMiUto U 

lata fall raa. wiatar rva. aab apriag rwa cklaaM aala^ la IfTa, fall rm 

apaaaiag apatrvM frM tto Ma aMk ar ii JS.53« Malta, lata fall rm flM i 

n.Ol* adwlta. aUt«r rva flM aiiakirii U.tit a«alta, 

7.03b aCwlta. Ia IMO. fall rM rblaaab rwM aara 21, Ml aCwlta. lat* fall rto aara 

«.3bl, vlatar rM war* 1.142. aarf apriag cwa wara a.SbS. bUla tto pri»artiato 

af tkaaa variaaa raaa taMa la vary fraa yaar ta yaar. it i* claar ttot tto lat* 

fall rM* hava graalir dlalaiabM. Mil* tk« wiatar rM flM ar* m tka varg* 

of axliactlM. Altkaagk tto /all naa c*1mM papwlatiaaa ara - "i riJ by batckary 

^adactiaa at CalaaM, tto atkar rwaa ar* <ipM<Mt apaa aataral raprMactiaa. 

Tka lata fall aad Matar raw flak ara Ugkly Iapartaat fa* irraat 

aa tkalr li/a cyclM ara wall amltM ta praaoat flaw ral«t*« pattar*. 
tto iaaM«mt* laMar* at kM blaf/ dlvaralM Ma a*M ta to tto aa>r facta* 
ia daatrwyiag tkair papwlatl^M. aklM avaa M ta c a M yaara aara bkaat CMbl M 
aiakara ta tto fall rM. 

Tto Agriaaiat Mawld alaa r aaair* BM W ralaaaa aaa^ta flaM far aalMW, 
•tMltoad. aad trawt papaJatlawa at It* friMt Ma aa tto Im Jaa^wia Uv*r. 
Ttora ara prvaaatly aa agraM flaa ralaaaaa at Frlaat Daa, caaattwctM ia IMS. 
oaapiu ita ■atarakaJ'araa af l.iTS aaaa r a allaa aad aaaaal flaaa at tto «^ 
«aick avaragM l.T Mlliaa acr* faat la 1*07. 79. M avarag* flaa W S,431 cfa. 
(OSB Mta) laflaw ta frlMt U wry atakla kacawa* af cpgalatiaa by larga 
raacrvair* *a ila topi* raackaa. BB praaaally Aivarta alaaat all flawa. mMa^\ 
dwriag aatraaa flaM atagM. lata tto Priaat-Cara mad iMMra caaala 



capa a itT 4.O0O afa. ' 
aatar la bbM far (r 



I Mvaralaaa tMa plaaa avaa ia wiatar i 
atac rackarga fw frawa ta Mkartfialb. 



IMa aatoMb MaataalM af tka Saa Ma tal ■ Uvar ia illagU aaMr CalUarala 
IM, MlM M "waaaatoMa am* frakibAtM by Article I, SactiM 2 af tto 
State QiaatlMtiM. Savtiaa StH af tto flM aM OaM OaM raaairaa tto aawar 
af bay Ma M ralaato totar airffidtot ta nlataia flak papwlatiaaa at ttoir 
klaiarU laaal. Mrwaawr, Sactlaa »14 ad tto fiM aM Mm ObM UlaM tM atata 
M aaa far M^^aa far aay aaM Matraatlaa af fia to ry raaaarcaa. 

Tka toll— Maatariat af tka Im liigilt Uvar la tka aaat flagraat sa^la ai 
BB vlalatiw ai atato aab faMral law, aab akaaia M ra*M l i4 m part af tto 
OaarMaatM Oparatlag Acraaaaat. laactoaaf flaaa to tto Saa Maaaia •*• alM 
MaMf to aaat atata aM SB Mtac ^aality ataMarM U tM Mlta. MMr praaaM 
df n— ttoCto, akawt T3 parcMt af flaw ia tto lawor raactos af tto Saa Jaato < a 
ara agricaltaral r«twr« awtar MiM aacaMa aatar aaality ataadarM dwriag aaMar 
aM fall aaatto. Aay lacroaM ia flaa aa tto Ma Jaa<aia cawld *«rv* aa a aaa 
aaarat af aatar far tto firaaaiaaM arM, akick aa laager caa m* aatar fr^ tto 
Saa laM Maia. BB eawU cae a w ar aay iacreaaM Saa Jaa^la Uvar flawa at ita 
Mlta i^iag plaat. ar Ball tkia totar to Sirf to atkar agaaciaa. 

Ikia Sm JtoMla Uvar flaw aakaacaaaM pragraa akawU M kigUy prafi table far 
BB, bb it iavalv aa takiag af aatar praacaUy aaU at a very lew price aMar 
vdatlaf aaatrtoto aM aalliag tkia aater ta SVf ar attor partita at a aack kigfcar 
Mito. *toiari^ MO cfa U aaw flaw ralcMaa. tUs aaoMta ta 130.000 Af flra yiaU. 
Aa tkia aater ia preaeatly aalb aaMr caatract far pertopa 12 par acra faat, ita 
praaaM Iiliii ta BB ia akaM 1700,000. If it Mr* aald ta Stff for aaly (30 
par acra iaait, BB rawaaaaa waali iacrwaM %a $7 Mlliaa aawwally far tkia water. 
Ikia itotraM flea pragraa aaalb aat BB aa aacb aa« flra yield aa tto caaatrwctiaa 
af Aabtoa Maervair. altkewt kavlag ta pay $2.4 kUUM fa* p*a>*ct caMtractiaa. 
It caaU blM M aaM m a aaawM ai aapply tma tka falaaa-Saatk arto. ^itM 
Aakara aaa Mal^M to aarva. 

Tka Sm '--t''~ Uvar, ia tM IS aile aartlM balM frlaat Dm, aappartM cklaaM 
aalaaa papblatiaaa raagiag aa larga aa 34.000 aaalta prior ta daa caaatrwctiaa. 
Ita priaaM aalaaa toaaalag papwlatiew la aara, accar4iag ta OK data, fre-prajact 
flaaa ia Mraal yaare avaragM 1.000 cfa JaTgiMkir. 2.000 cfa ia fabrwary. 
3,100 cfa U My. aM 1,S30 cfa U A^wat. IvM ia dry yaar* flea* avaragM 1,100 cfa 
ia Haveaka*. 430 cfa ia febraary, l.bOO c/a la My, aM eob cfa la Aagaat at frlMt. 
(Jaaa* aM ilabea. 1*TT etady) A*«rag* flM la l«OT.)b at friMt waa 2,230 cfa. 
Ia a an irately Mt y*ar. l«33-3», a*M aMtkly flewe Mrai Octator - 1.122 cfai 
Mvaabat . 1,011 c/*i DacawMr - 7*3 cfa; Jaawary • 403 c/a; fab. - 3.1S2 cfa: 
Mrck . 2.TT4 e/*: April . 4.974 cfai My . b.OU c/a: Jam - 4,304 cfai Jifcly . 
2,3bS afai A^aat - I.SSS cfai Saptaaba* . I.IIS cfa. (BOS g«ga Mta fa* 143») 

to MUeve MaiaM flM r*l*aM* akaald to la tto viciaity af 300-1,000 cfa ia 
arMr ta fmlly r««iar* tto /iatory ta aaar Uataria level*. Mtctory cetotractiea 
vwwld alaa to ca^ulrM, •• frlaat baa blaMM flM paaaage to aar* tkto 144 atraaa 
Mlaa M it* aaia atM aM aa>( farM. 

It akawld to aatM ttot aar prapaeM atraaa flaw labi t pragraiH are geraaaa 

ta tka iaato ai tto Maft SOi tto ariiiaU Ma/t BIS, -bvlraaaaalal StalawMt m 
tto AeaatkarlaatlM af tto CVf aM tka OaerdiaalM Oparatiag Agrvamat far CVfawT', 
iaaaad ia AUy 14S0, cav«rM tto aUaaw floa laaa* «itb tto fbllewii^ relaaM 
r*aalr*aMt*i Aaerlcaa Uvar - 230 c/a Jaaaarr-Sapt . 13t 300 cfa S«*t. 1*-D*c. Hi 
tacraaaata Uvar . flewa raaglofl 2300.3400 cfa: Triaity Uvat - flMa rw^iag 
130-200 cfai Qcar CraM - 30 cfa JM.-OcteMr. 100 cfa kav. PacaMar; StaaialaM 



111 






■ l*«r, «MM»tr«M (r« OMl'* Mm MvImm t«Mrv«l<, 1.4 aAUiaa Mn /••« •««*«#• 

ckpMltr. TW llkAlaiM* h«« » «*ftiM«« w«« •# ••• •«««• ■dla* •! Mm Mil«*M 

IB « MteffKttly Mt p«u. ltU.M, il« SMS #1«M •! tk* •!« Hal*M« pmmmthmmtm 
f9tUl*« l.UO.OOO Af. wtib tlmm rM«i^i Oat. . »• i/»i to*. - U4 c/«i »M. - 
1*0 c/ai r«b. . 2.M} cf»i Mu-c* - I, HI c/«i A#tU - «.4U •/•) May . S^IOS cfa« 
.Na«. l.OM ci«i .talr . 1,1*5 cisi A«CM« • l.U« ctf*: tifliMM . Tn t/«. 
CUBGS !•«• telft /w ItM) 

U cMirMl. /!«■ raiMM* talw CiiUta Ibk, itticb >Ii^i Mian m« •iMlfcMtf 

• i«r«ilM« MlM MM Mtl«M«, w* U«blr M#rUiOTM. PlM* La lf7«-«0 Mr* Ml? 

4 tit tecUc MM* af OctaftM. 14 «#■ *wLat Mat •« >Ma. m^ avaxM** a^T 

M c/a U Aafwt Mri 13 cfa U S«»t«M*M. ftwl^ ■■■« ^ Um yau, faari M«a« 

rclaaMa accafra* m Laflaa ta Haw MalaM* mj 1, MS, 000 AT a^ Mtar ralMaM 

>t Cn a^w U Das i*t«Ua« 1.010,000 Af. «itk a mm Am atf 1,>«1 «/a. («« IMO te«M> 

Ap»afMtlr tka flM ralaMa m«Mm Ilea ia il giaiH raUhM «Mm avUlafeAUtr 

a/ Hatar. 

Ptaaavt affa«« flM falaaaaa Om Mm Malama, m MMMart talM Oaa^Aa iaa. 
MOMt ta M.OOO AT la aMMl rawa. altfe flaaw atf 113 c/a HaaMT-*>y. IM c/a 
Jm* t a»iMMf, aarf no c/a OctaWy DaiMfcar. It *««14 to Mtatf ttet lUa llm 
^<««-Mt. alpM« im 1«*4. Ma *LaUta« fa« k latAl o/ lAl Mra U Mlw r«M 
irr^ao. Ail tft«M Mya «/ vlalallaaa vara axtraaair fl^r^, vttli ««laa*«» 
(aa«la« 4-M c/a aiwa tka /1m afrMMst c*lla« Im tlmm n^l^ 12S-100 c/a. 
TWm rt«Ullaaa aara saaAaM, aa Mat tellf /laiM U Uta I 
Mra avar 1,000 c/a. 

TW ^aaairt /las fl^^m a«ra«MBt la hlgUr 1 I'lpiili. ai^ 

kllMia« tlmm f ba ta««ca4 ta SO c/a la Jm^ ia»tM»M. UO c/a Octai 

u« 100 c/a J iaMXT-MiT. OiMa that iMaal la/lM ta Mm MaiaMa avancaa l.TU tfa 

kna Ikat tUa b««a raMrwalr la «a#aUa a/ rax«««latia| all la/laaa. m M11«m 

that iMlraM flM ra^alraMal* MIm CiiMla »m Ma^l* Ca at laaat 300 c/a 

FMr a(aM«. T^m kl^Ma* tmx ar«M« /laM ara rutlc»lAr>T McaaMrr ta »r«viM 

a p iMla t aa« raaxi«« bakliat /ac ataalaaa«. m mH u UftfMil^ atMac raccaatlM 

ttaaa a/ Ihla atiaaa. 



rra-pr«iact cUaaa* ai l aii rMa, Midi M*a »tf*«iMlr a//aclatf by a*«llav dmm 
and dlvatalMa amA a« CaaMta »m aari tba aU Milaaaa baaavMlr (lU.OOOkV), 
aMMr«4 13,000 a«alta La 1«3, »ltb nsa avwa«li^ 4.000 atelta U 1*31, 1*3T. 
and lf3». Ia cMtraal. U l*T*-« aalMa cmm raa««i /rM can /la* U ltT» ta 
110 adalta la im.fDIC «ata} laaad m mairiaaa »ltb tlM E^rlcM U««r, aMioM 
tiu ailaia naa a*«ia«LBt 30.000 arfvlla a«a aiMl^aad rMa aMfa^lac 10,000 aiteitb, 
tha StaalalcM allb t*m tlmm nl—mm caaU i^iiii iiHin 23,000 iiliii aa« 
3.000 alMUaaa. 

A Mra MtLnU flM ra«lM m tfca StaalataM UmmX* aat ba ««tri«Mtai ta IBM 
aparatlaM, aa *«t a^AltlMal Mitr ralaaaM ca«l« ba faca*«ra« at tba cvr a^ 
Swr aM^ la iba 4alta aatf aai4 /*r a blghat ptlc* tta« ca«U ba abiilaa^ U 
tb« StaaUlaM bMla. 

0«r pripaaM /Im ra«lMa m Claar Qraa*. Aaarlcaa U««r. SlaalalaM Uv«f, aM 
Saa JM»iia Um*. ta««that arltb tb« tMm aAtliatlM i 



^ mm M.J. M* ^ HUAlifa AarviM, <««1« ^atMtlallr S*^ 

^ ,1,,llin" U CMtfbl faUar rlMta. Tka CMcAlaatad ^aratias 

•//ara tMa baM Mltr *•• ••»»• — '•*«»i '*•* -^ wL141U» 



«aMiM ta iiMliii 



,^ pr«»M ■AtlfatlaM faa aviatii^ cr>.*VF /acilltiM. ■■ baliaaa 
aM ba attbiMtf ^tbavl t«Mt eaat ta UK aparatlaM. aatf 
^^ acUa iilii tm aa ^iiMMt that wmmlM baMt CV»-«W 



rlaU 



> I ailUM aava /aat U 



^^^ 



torU tan«r. »t JMM «. CU/Mml. *.*<. .f <k<o bMwca. 

J.<1 Mnall, MnrU«, OkU/M«U >w<. rf »* .M CM. 

t^iM.i Miw«.. 0,1. ■««• .# ■ . .! ■■■ ti.» 

,Ha M milt, •••. H« M« MUIU. f.TVin 

t^. tliitii. K«l/1« OnM »ilmtf .< riAma'a CulMtlH* 

UA Mr, tllllim, Ml/Mai* Tr«M, IK. 



S 



,i^ 



CALIKMtNIA WATfRIOWl ASSOCIATION 



Occob*r 2S. 191} 



Hr. lDb«rt Schro.d«r 
U.S. Bur««i of t.cl.a.clon 
2800 CotCM* ^7. tMm U-21)7 
Sacranto, Cllfornt. 9)S2] 



Sub], 



Draft ItS/IU on cha 004 



- j€S 



a^ i«;?i' 



Dmt NT. Schroaan. 

Tour draft IIS/IU haa baan rwla 
prahanalva aad thoroufth. 
It la aarloualy daficlaBti 



•4 aad to ganual It la com- 
tbara ara four arMaa in vliicli 



Tha antlra dlacuaaLoa of tha CQA'a iMpMCta and raLatlooahlM 
CO tha Sulauo Harth ara baaad upon tba aaakaptlon that Cha 
fouT-parCT aarah ajrra^aot vlll ba aUpiad. Uhlla tha currant 
draft g-i i-i-T ia accaptabla to tha four »artlaa. it cannot 
ba la«>l«aancad without Cooitraaalonal action. Thara la no 
aaauraoca chat chia vllt ba forchca«iii«. Am tba raault . In 
ordar to aiUquacalT a^raaa cha Sulatm Harah laaua. tba 1X8/ 
en mmt avaiuata tte affocta of tba CQ4 on Cha Harah ia Cha 
abaaoea of tha four-partr acraaaBnC. 



Tha aaccion on p«caa 92^ 



.00, _ 

"17 iToaaly 



Kitiaatiop Waaaura» 
"" uata. Tha conatruc- 
in fubatantlal 



for CJMulaciva I^>acc« , 

Cloo and oparaclon of tha Off baa raaulta 

watland loaaaa in tha Frojact'a aarrica araa. Thaaa Inpacta 

hava oanrar baaa nltluCad, aad tba nitiiatlon naAauraa aaction 

on pa^a 97 doaa not diacuaa tba nnad Co do ao and altamatlTa 

waya of accoapllablns It. 

Tha lann il of Cha HoratOTiun on Paw Watar Sarrica Contracca 
U^ t lftft »ft MftA* ^;-V hM* i *ai'l&ui mie lt^y. t^ia ftt gh4 
■ora logical loraa of nicl(«cLon would ba Cha uaa of CV7 waCar 
and powar to prorlda cha wacar atippUaa a*caaa«r7 to naincaln 
cha ra«ain1rn waclanda in cha CTP aar ric a araa. Lifting tha 
laoTacorlvM and aala of tha raaainiag CV? yiald without ra- 
■arvlng ttM wacLand wacar would affactlvalr aliainata thi* 
approach Co providing nlclgaclon. Thla auojacc and Ica raa- 
Iflcaciona naad Co ba thoroughly axpLorad in cha aacCion 
daaling with tha TaaowaL of tha now watar aarrica contract 
noracoriia. 



4. Tha aoccion on 
followln( acacj 

"Tha cocaa of cha ■»racorl\a prorldad that It would ba 
llfcad whan cba raaponalblllclaa of tha CVT coward wacar 
quality protaccloo in cba DalCa had baan clariflad and 
Cba Bura«o bMd coaslccad icaalf co naac cbaaa raapon- 
alblllclaa." 

Wiila tba acatiBant Itaalf la corract. It convaya a totally 
nlalaadlng lapraaaioa that tha aicnlng of tha CQA would 
■aat all tha condldooa aatabllahod for lifting tha aora- 
CorltB. Tba addlcional coodltlona atilcb bava not yat baan 
■at Incli^ai 

A. laauChorlBaCloo of cha CVP co naka tha uaa of CVP 

wacar aa^ po — r for flab and wlldllfa projact purpoaaa. 

I. FraparatloB of laglalaclon which provldad a guarancaad 
vatar supply Co Racloaal Wlldllfa tafugaa In tba Cancral 
Vcllar. 



Tba III/IIK naaAa co no: 

baan nac and dlscuaa In 
falling CO do ao 

Tba Aaaoclaclon appraclaCaa Cba opporcwilcy of providing thaaa 

' bopas chac cbay vlll ba b * ' ' 
cba fla*l lis/lbt. 



Inc ouC chac Chaaa condltlona hava not yaC 
daCalX cba aBrlroDMaacal conaa<}uancaa of 



and bopas chac cbay vlll ba balpful Co you in praparlag 



Vary cruly joura, 

D. Chayta,' Chalraaa 
laaovrcaa Ce^iltc** 

cei Karl Hliiklai'. DWt 
Jla NcIavltt.USrWi 
rata lontadalll, DTQ 
CH4 



112 



Committee for Water Policy Consensus 



•UUMM 0< 



toe tha 



» II n 7, ins 
Ooaowtf, Ollfacala 



Tha CoiKlttn (oc UUr roller Cansnaiu (OKI !• a bio«d-b«a«« and 
balancad froup of dlvocaa iatacaata fcoa tiM ll- c awty tas rraaeiaa* 
Bay-Dalta aioa, a ra^lea that la boaa to aovaa Kllllaa poo^a. flUa 
cx^tcao at piaallc nd pclvata laadara *—•*—*■■ alactad offlHala, ngnam^ 
tatlvaa trtm fauaioaaa, Induatry, lafaot, i«tac afaaciaa, aavlraaaaat*! aad 
public lotaraat orfanlaatlana, aftlcvltiirml la««c««ta. tka mm^aale aem- 
BBlty, aad ladlvtdwla with latar 



Iha prlaarr 
Matac policy 
procactloB. 



o< tka oac atiaa It i 
■a that ra<Ucta i 



dc a<tlciaMr aid Motn 



-nia aac la atronily o^ttad t» aaorlai pnlailliBa Cor diittiia GkUtaa- 
nia and tha Ian rraoclaoo aay-Oalta ca«l^ kofoc* t*Bf» la ai^ locnaao ia 
tha laval of ai^ona e« of tka nlu. ■• aaa tka eadaral-atata Oooidlaata* 
OparatloB JI9raaHat (COkl aa kaUi| a crltlcaUy b^octaM *ar-Oalu prata^ 
tlca aoaaiico. aa aopvort hotk tka OOk a^ ■.(. lUI, aalkailati tka 
kaerataiT oC tha Utorlai t> al^ tka OOL 



i<186^ Inaa Caul. S>ila tUl Catcaa OMarta 94530 • (416) M2-66U 



■r 7, ins 



wa aia aatraaaly plaaaad tkat tka todacal 9ovo u — r i t Uifouqti tha a» and 
l.l. IllI no> haa aada a eeaaltaaM to pcoirldlag ita ahan of <rotoc qvllty 
pfotacUoaa toe tka lak rtandaco Mr-Oalu aatuaclaa ayacak. la ai n ai l aia a 
trttk atata-dataialaad ataadaida. 

■a ata iwiraiaill. koi r. tkat tka COk Itaolt doaa not ecHlt tha fadacal 

|uiiii—a> to aaitlat facan naUt vallty atandanla aat by tka (tata aatac 
■aiiMiiai CDDtrol ioafd (aacBli tha CDk only obli^taa tha o.t. kufoaa of 
■ai laaallMi to aaotlaf tka eaxraat ataadarda aa cootaload U tka MO' a 
Oadalaa 1419. Wiaai ataadarda an aapaetad to ttitnrt irtthlii a fa» yaaca. 
Moaitkalaaa, tka OOk aaaacadly i i »i aaM « i a atap in tha tl^ dlractloa and 
aa wlak to ooaaaad tka affotta of tha (adacal aad htata a apottatoca la 
bcla«la« ataut tma kUtmlc i|iiiaial. 

It aaat ha aotod that aa da tmm aoaa coacacaa about tka dcaft IXVlia Cor 
tka can. cur aa)or eeaeata f D c aiii oa tha aaat^ptlaa la tha uwia that 
tka Daclaloa 14t5 aatar quality ataadarda provl^ ateqimta protactloaa Cor 
tka lar-Calta aataailaa ayataa. It la elaat to ua that tka Daclaloa lUS 
ataada i da do aat ada^uataly protact tha aay-aalu aatuary. tta korrwidaur 
daellaa la tka Mrlpad (aaa ladaa (ml la m^alllnj avldBKa od Ihla. Sa 
■■ca aat a faal la KTI Cor a (ttlpad *aaa ladaa oC 7«i tha ladaa kaa 
daellaad pcadpdtaaalr to t.S, a laoal oMa loaar thaa dullnf tka ir7«-T7 
d, la tact, tha loaaat polat U tha hlatacy d tha ladaa. 



thla altaatlaa la aat aecaptabla aad Daclaloa IMS Biat ba aadlflad to 
UMaca tha kaalth o< tka atrlpad baaa aa <mU aa othar flak and irtldllfa la 
tha aataaiy. JIddltlaaaUy, oadalaa lOS doaa aot laduda adaquata ataakrda 
tlk. Ml naadaoo lay, ad tka leath Dalta. naaa l i a i l apl laa 
ad la tka *U/*a. It la arcaf to aay that by alJ^y aai ( l n ) 
I 1«S ataadai*, tka lai Pilta aatsafy olU ka protactad. 



■a alaa aata that Daclaloa 14(S aaa lajactad by tka •upacloc oaart aa 
lapcoyaflr pr^alqatad. It tka at/m la to aaka tka aaat^lea tkat 



@ 



aatlHny 

at 7, ins 



: laatlaoar 
^ac 7, UM 



Daclaloa 14tS adaquataly pratocta aarliiiaiilil aalaaa, thaa datallad 
IntocaaUoi auat ba pteildad ta dDoaaat tha aallditir a< «*ta aaa^ptlaa. 



liddltloaally, tha nvm MaaU ha>a i 
rraoclaco Day of dlvaralaaa aada by t kaaa caa aajac aatar ^ajaata. 
Infotaatlea oa tka af fact oa tka aataary ad lataaa Oaaa tx^ afiliallaial 
■aatoMtai ill ilia pi Ciaa tha daa Joa«iU «hUay alaa riaaU ka laeladad. 

Tha oaa provltea Cor afiwtalMtaly nt.Md a >' ia > aa t ad istar ta ka "aada 
avBlltflU' Cna tka Caotial vaUay na>act aCtar aaaoaUa of tha I 
Tha dcaft at/su dlacaaaaa poaalh 
othar coatcactara. Ha nvczi Moald lailiill an aadlyala ad tha haaaClta 
to tho koy-oalta aatuary It tkla aamat ad istac aaa Ma^ ta l ^au aa aabac 
quality U tka aatuary — ahaia D a rt alaa 14*S tm^itt — by aUaalap Ua 
•atar to floa tkrau^i aad cat o< tka Oalu catkac thaa balap aada anllilila 
Cor aiport out e< tka Dalta. Ha aota that tha aconoic (kaa^ «a ta loaaaa 
la tha atrlpad haaa, chlaook aalaoa, and ataalhaad traut Caotral Vhlloy 
flahaclaa aaaata to 1117 allllaa a yaar, alth aa aMlUaoal loaa of MM 
alllloa la raeraatla kaaaClta. Ihaaa ata loaaaa that alll ba aaCtarad 
aaaaally aa loaf aa thaaa thraa Clahadaa raHla at Ikalr iiaiaal dapraaaad 
lavala. (tha aonroa oC thla laforaatlaa la a rapart praparad by Rayar 
kiimrraa tor tka CalltotaU Drpailaiiil ad HA aad Saaa. I 

Anothar auqqaatloa Cor tha Ud/in la that aa aaalyala at tha aatlaaa 

Bthote by idach Ua m oaa ha toralaatad, althar aillMaraUy ac by both 
partlaa, ahoald ba provldad. Ihara apvaara ta ba aa » a ral aaya tec tha taa 
partlaa to taiaiaau tha ll«raaaaat. 



Ihla coaela 



dttao'a faaaral i 



1. Paqaa 14 thtoaik M dlacaaa koa opacaUaaa af tha taa pre)acta, U 
accord^sa vltk tha OOh. aay raault la aa lacraaaa la taaparataraa 



i lw ai lrf a< Caatral «Uay fn)aet l aaa i a ul ra idtldl aay ba datrlaaa- 
tal ta aalaea. u thaaa paqaa, thara ladka a atataaaat tkat la latar 
teiad a paga 77 tkat "COocdlDatlag cparatlona o< both p ru> a cu to aaat 
thaaa ataadarda la Judpad aora banaClclal to aalaoa OMraU tlaa IC 
thaaa ataadarda an aat aot*. it aoald bo uaaCul ta laduda thla 
■ t i l Miil U tha dlaiaalia a papn M thaaa^ M. 

>■ OB papa 42, thara U a parafrapfc caacaralap Dalta auttloaa ta aulam 
■ay, tea r rwri aao lay, aad ta tka aoaaa, atatlay that tidal mriiiiaa 
taad U OTCfidalB fraak aatar floaa caoa thay fat bayoad tka Dalta. 
Ihla lapllaa tkat Dalu mitflnaa an laal^Clcaat ooaparad to Udal 
l afl aan r ai. Ihan la ao i lr ii i aa a auon to tbam tkat tkla '-—rliaiia la 
cacract aad It atvaan ta ba oMradletacy ta mini cladlapt — — — '-y 
tka aaeaaalty at Ooaa ta atrauty aarlooa prta c< laa rraadaco lay. 
naah aatar Oaaa an Uvortaat ta tka baallh at tha lay. 

>■ oa papa 74, tha atataaaat la aada 'To tha aataat that any aatar 
aand by aparatlap toe tha Tracy atandarda cathat tlaa toe tha Bddblt 
h (Dtdaloa 14«SI atawfcnla aoald ba ralaaaad Inataad o< ratalaad la tha 

■ aaa nul ra, tha aartiiiaailtl i iiiiiiip ■■ ad m actloa lauld m-— *■ 

thaaa at tha PtapoiiJ hetlea aa far aa rlvara and raaanalra ara 
oonoaraad.* Ihla atataaaat aay ba ooccact tor rlvara and raaaraoln 
upatraaa of tha Dalta but la aot ttua tar tha aaaUca DalU aad tha 
aataary ayataa dnaauaaa ad tha aaataia Dalta idddi aould ba admraaly 
atfactad by additional dlxcalooo troa tha Dalta laaaltlap ttoa a 
ralaaatlca cd Mtar ^Mllty ataodarda. 

4, (M pata (4, thara la a abort dlaeuaaloa concaialaf rrlaat Daa «d 
MUattca Uka. rrlaat Dm la looatad a a atraaa tributary ta tha kaa 
Joa«aa llaac. <ha baa JoaquU Uiar la aaa o< tha myx ulbalarlaa 
to tha Dalta. JIA aa pl aa l liai aauld ba aada aa to idiy aatar dlvaralv 
facUltlaa as tha laa Joaqala kl«af (auch aa rrlaaa D^ and Mw nalcaaa 



113 



M 



DM) •» not voMCMd by tkls MrMMat Mi «ki 
to cootritauta to ■■y-Oklt* —tot ^alitf. 

in concludlMf fwr coaaMita la tha tfratt nvvXB, 
■onltor with Intorsat tlw pcofr»— tm Xim nwiillMlaJ ( 
MB looii tonard to tko fa4Brftl-«t*to prt— tiiaj U i 
by tho GDft. 



nJefcndcrs 

-y OF WILDLIF 



IX 9, 19t5 



Hr. lob SchrowUr 
fci f u of It]— clj» 
2800 CottAC* U«7, tool 
Sacraaaita. CA 9}8U 

Daar Ite. ftcfaro«4«ri 



'^IWll 


■s 


^" 


— 


^5P 


7/tt 

















































■>?• 



^ 



Datawten o< WtldUC* (lAatu cht« !• 
caeo^MBdatlooa oo tb* Draft torti ii— iril Ii^aet t ufit aiA 
riiilmiMiinl I^att lavoTt CBU/Ilt) aa tha frataaad Coortflaata* 
O^ratUo Airiiiiiit of tha fatfaxal Caaxxal Tallar rnjact (CVr) 
•atf cha CalLfonaa Itata Watar rnjaet (10). Ua ra^uaat that 
Ua> lactar ba lnrliiiU< U cba pufclta raao T < as thta KU/tlL 
Thta Lattar U alao Utanilai ts ani|llMif aor vaxWl eo^HBta 
at tha Octohar 22, KU. haarl>« ta In i ■■■■»■ 

At tha outaat. Dafandna of VUdlUa Wltavaa that Cka | f D»oia* 

Coordtnatad Orazatloo l>iiwnt (OQA) U paaxallT < poattl** 
■ tar to aehtara naoaaaarr protaettM (or Dalta aatar roalttr md 
aaaocUtad natural Toloaa. Ha a\«ort thla p iu |i m i C04 (aa< 
B.I. 311] pandliu U Coi«roaa> aa far aa It (oaa, but it doaa 

not go far atwugh. Daaplta our quallftad aimort for thla 004. 
EoMvar , m ara <lla»polnf4 «lth tha graaa Inada^nanlai of tha 

nis/iu. 

lit (timlr baltam that thla KU/tU teaa aoi ao^lr >tth tha 
laval of candid and co^rahaaalvn analyala raqulrad mdor tha 
■atlonal Iiii 1 1 iii^inl >o1Ut *ct (IDA) aal tha CoiaeU am 

toTlr- ital QualltT (Ciq) tuldallaaa. Ones tha OQA la aaa- 

cucad. cha Buxaau of iaclaaatloa (luraau) Intaada to lift tba 
praaaoc aoracorlia on aacarlac additional lana*taxa watar aarvlaa 
concracta (or tha cvr Thla action «lll tat In aotlan a aia*ar 
of ■tpitflcant advaraa jarrti iiiwaiif ll Ij^aeta ahleh haaa not 
racalvad adaqoata conaldaratloa. 

For aza^la. tha HU/IU Inoludaa lyya n d ll S with tha 
"atoloalcal Aaaaaaaaat of tha Ia|>acta of tba Coordlnatad 

Ofiaratloo Aari 1 1 1 II t Co radazally Llacad Thraatansd or BadaBcacad 
Spactaa " Ttila appKdla araluataa poaaUla li^acta on llatad 
and caodldata apaclaa which prlaarllT occur In tha Dalta, lulaua 
watlanda. and alcoa cha Sacraaanco and iaarlcai Urara. Itafor- 
C\matal7, thla avaluatlon co^Lacaly oalta conaldaratlon for 
' which an 



I- 

r 



ochur lUcod and caadtdof ap^cUa < 



ara lUaly to bo 



od««ra«l7 affactW by additioaal wacor coatractLac aad coocoatcJAC 
acrlculcaral davalosaaat . On p«««a 97-99 of cba DEIS/EU, It la 
coacadad that i aii—iin cha ■oracorltm oo oaw watar aarrlca con- 
cracca eoul4 facllltaca a^rtculcural ajipaaalao in aavaa aarvlca 
araaa. Soaa of chaaa aarrlca araaa, partlcularlr thoaa to cha 
eaatral and aeuthara portlo&a of cha San Joaquin Vallay, coacain 
dvlndltac raMMata of crlclcal hablcac for llacad and candldaca 
apaciaa. Tbaaa apaetaa tncltida cha San Joaquin klc fox, blunt- 
Doaad laopard liaard, cha Fraaoo. Tipcoo, and gianc kangaroo raca , 
aikd aanx plant aj>aciaa. furchar, aoao of cha liacad and candldaca 
■paclaa wnlch itara araluatad la Apoandlx D occur In thaaa raglooa, 
buc advaraa li^acCa tnm adiUctoBal wacar eoncracta vara not 
cooaldarad. 

OTA aad CIO t^^^^L^A** raqulra dacallad oooaldaratloa of ciMulativa 
iapacca. aad «a uadaracaad that a taconc fadaral court daclaloa 
aLao aanrtataa cha araluattoB of a 'Snrac caaa acaoarlo" altaraaclTa. 
V* balUra Chat chla DIU/IUl tCDoraa thaaa Madacaa. 

Xc la claar, for axai^La, chac asacotloo of cha CO* and raaorinf 
Cha addltloaal wacar coacracclnc aoracoriiM la a pivocai junccura 
vlch profotBd, loof-cara wirooal iapllcaclona. both tor cha 
Dalca and throu^Kmc aucb of tha Sacraaanco and San Joaquin Vallaya. 
Indaad. auch of cha raaalnloc andanforad ipaciaa. crlclcal habitata. 
vatla&da, aad riparian ▼aaocacLon could ba laopardlsad by bqch 
afrtcultural axpanaion ana incraaaad coopaclcioo for llalcad 
vacar auppllaa. Oofarrinc coaprahaaalra analyal* for ac loaaC 
aavaa waCar ■axkaclng aarvlca araaa on a acagtarad and rogion- 
apacific haaia will ooc prwlda for an accuraca aaioaaaant of 
cuaulaclva and grxnrch- Inducing lapacta. Thla DKlS/lIk. aadly 
faiXa to addraaa chla oaad at thla cnictal daclaloa peine. 

Aaochar ooocara la cha baLatad coi^llaaca wlch cha Fiah aad 
Vlldlifa Coordinacioa Acc. Ua hava ravi«w«d a draft copy of cha 
U.S. ritb and Wlldllfa Sarvlca'a (FVS) Raporc and RacoBandaclooa 
undar Chla Law. Ua do not yat know If chli taporc and aacoasan- 
dacloaa has baan officially cranaaitcad co cha turoau. Id any 
avaaC, cha drafc kaport and Racoaaaodac Loui concain aany aarloua 
concama which ara ooc adaquacaLy addraasad In cha DKIS/EIK. 
Ua acroQgly rai imiiiI chac cha final IIS/IIE provlda full and 
hooaac cooaidaracloa of chla laporc and Baca^Modaciooa . 

for axa^la, cha drafc Eaporc acacaa on P«ga 3 chac "for aalnca- 
nanca of wlatarlng habitat In tha Cantral Vallay for Pacific 
riyway watarfowL populatlona. Ic la aaianclal chac a firm aupply 
of CVT wacar ba providad Co aina wlldllfa rafugaa and two wacland 
aaaasaac araaa actaaaiacarad tatdar cha National Wlldllfa kafuga 
Svacaa, and to chraa wlldllfa aanigaaaur araaa a<teinlacarad by 
Cna California Dapartaaac of Piah and Gaaa." Thla coafMlllag 



CALIFORNIA OfFICf S«04 «OSf DAif WAY. SACRAMCNTO. CAilKMNIA 9M22 • (91ft) 44I43M 
NATIONAL OFFICE 1244 NINETfCNTH STREIT. NW • WASHINGTON. DC 200M • (302) U^MIO 



114 



conc«m raUclag Co tb« haalch of ■lllloiM of Psetfte flvj 
wacarfowl and ahorablrdj, and tho fat« of watlrad* oo aUCa and 
fadaral rafucaa. la not racoacUad la th« DCIS/lIt, daapita tha 
face chat adaiclofiAl vacar coocracclac would raduca Cha avatl* 
abLllcy of CVP watwr which could ocharvtaa ba avallabla for 
rafuca purpoaaa. 

Dafaodata of WlldlLfa eootlau«a to ba appalled at Cha failur* 
of both cba IncarloT Daparcaaac and Coacr*** to ap*ctflc*ll7 
raaolva Cha parannlAl quaaclooa raLaclna co CVF auCborlsACloa 
for flah aod wlldllfa purpoaaa aad cha I«val of watar and 
povac which ahould b« provldad for rafu^aa. 1q a Draft Incarlor 
Sollcitor'a OpUioo of July L6, 19M. Lc U concludad Chat CVF 
wacar and powar can lagally ba provldad for flah and wlldllfa 
purpoaaa, but ic l« unclaar how chla auctwrlcy abould ba mmmx- 
cLaad. Ic la aAdly Ironic cbac whlla cha luraau la anxioualy 
■walclnc cha oppommlcy co axp*dlca axscuclon of additional 
vacar sarvlca concracca for a^rlculcural and ochar cuacoaara, 
chara appaara co ba a acal^uca In raaolvtof cha qu«attan of 
CV? wacar and powar for flah and wlldllfa purpoaaa. Of couraa. 
■• chaaa additional watar concracca ara axacucad. and Cha 
fiuraau grachkillT raducaa cha current 1.000,000 acra faac of 
•urplua CVF ylald. cha opclona and available waCar to addraaa 
fl*h and wlldllfa oaada will diminish. Ua boLUva chac cha 
:0A and chla NEPA avaluaclon provide cha only Baanlnftful oppor- 
tunity CO honeatly addraaa thasa concama , and hop«fullT perauada 
the Interior Dap«rcBanc and/or Coagraaa Co aaclafaccorlly raaolva 
Ltiam. 

The DEIS/EIR Ilaca a niabar of acace and federal lam on pa^a 99 
which thould provide anvlrooaHnCal aafaguArda. He ■alnt^tn that 
cbtaa lawa. and the Incant of both Congreas and Cha Callfomln 
Laglalacura haa b*an to require laaa daBagLna altamatlvaa to 
propoaad projacce wherever poaalbla, and Co fully alclgaCa 
unavoldabia advarae lapacca. Exacucloo of COA ] aopardI«e> Cha 
fucura availability of wacar for fadoral and atata wlldllte 
refuge* , and other wetland and riparian hablcaca. Tb» OCIS/KUt 
do** not addraaa thla problaa, nor acknowledge Cha LonsaCandlxkC 
debate on CVP auclwrlraclon for flah and vllallfe purpose*. Ua 
fael chac the laws deacrlbad on page 99 ahould ba racoocllad 
In this conCaxC co daCaraina chair appllcablllCy Co aalacalnlnc 
reliable wacar aupplla* for scace and fedaraL wildlife rafufaa, 
aa well as dwindling wetland and riparian hablcaCa. 

Thla analyala ahould aspaclAlly Includo Cb« Endancarad Sp*cl«« 
Act, cha riah and Uildllfa Coordination Act. the MlKrator7 Bird 
Traacy Ace, and coa^lianca vlch th« aaparata craatlaa with 
HakIco, Canada, liiaaia. ai 



12S 

4. 



Since MEPA and cha CIQ guldnllnaa raqulra Che evaluacioo of a 
raaaooabla array of altamatlvaa, «• racoaaand Chac a "fish and 
wildlife protoctlon" alcamaciva be developad and analysad. 
Tba brlsf and curaorr axaaination of a alailar "aodlflad" 
alcanaclva in cha DtI8/IIK la patently lnad*quaca. Tba 
alcanaclva w« aavialoo would fully daacrlba cha lagal and 
policy juatificatiooa for laplaaantin f cha CVP auchoricr co 
provida watar and powr for ilsh antt wlldllfa purposes by, 
•aonc ochar thinaa, rasarrinc at laaat a half-aillioD acre- 
feat of CVP surplus viald for rafufas and aaaaaeot areas. 
This alcamaclve would co^ly wlch the envlrooasntal laws and 
craaclaa BaocLonad aarllar, and aaaure ■alncaoanco of Pacific 
Flyway wacarfowl an d s horabird populations. Olscuaalnc this 
altamatlva In cha UPA foraat would also bopafully foatar 
soaa canglbla action by tba Incarlor Oeparcaeot and/or Concraaa 
In arrlvlac at a raaaoaabla aattlaaant. 

Tha Mil/Ill abould avaluaca cha prospacca of axacarbaclng Che 
cuTTSBt agricultural draliwacar and salanlia problaas co cha 
eMtaaC that any additional watar aarvica contracta encourage 
expandad Irrigation on areaa with tainted soli. SLallarly. 
It Bay ba desirable to dlacuas tba aconoalx InpacCs of such 
agricultural expansion via-a-via aurplua crop a , faca prlca 
support*, and below-coeC wacar pricing. 

Plnally, tha San Luis Rational Wildlife lafuge nay aerve aa an 
exa^le of a problaa which could avancually bacoaa e aajor wild- 
life tragedy. If not raaadlad. Dua co a daclalon to scop using 
contaainatad drain wacar co aalnCaln soaa of chla rafuge s 
weClands, alternative water aources were sought. Ac chls 
writing, cha rafuge has reporcadly ooc racalvad raplacaaanc wacar. 
and. cbarafora, nany foraar wetland habitats ars now dry ackd 
unavailable to provida for cha oaeda of hundred* of chouaaods 
of waterfowl and ahoreblrda which are arrlvlag during this fall 
Blgratory season. This problaa ralaao an OBlnoua danger sign. 
Tha Intarlor Dapartaaoc and ochars have bean saveraly crlclclsad 
in tha aadia and In Congrss* for falling to head warning signa 
relaclng Co aalanlia conCaalnaclon In tha nearby Kaatarson 
HaCional Wildlife Bafuge. This highly-publlcltad problea wes 
focused oa wildlife deachs and daformlties on about 1.200 acres 
of habitat. In concrast. ww may axparlance the future de-wacerlng 
of parhaps Chouaands of acraa of rafuge habitats. If Cha CVP 
coocama raised aarllar ara noc pronely and adaquacely resolved. 
Plaaao consider thla latcar aa "Docica" of this pocantial iapand- 
tng wildlife tragady. 



njefcndcrs ^ 

-V OF WILDLIFE 



ThAkk you vary such for < 



aidartag our vtam. 



11, 1S«5 



^f^"^^^^ 



Sincerely. 

Klchard Spoccs 
California Rapreseocatlwa 
Oaf andars of Wildlife 

U/Js 

cc : The Honorable Donald P. 

Sacracarr of cha Interior 
Tha UonorabU Ullllaa P. Bom. 

Aaslscant Secretary for Plah and Utldltf* «b4 P«rhj 
David Uouaton. Regional Dixactor. 

Bureau of Raclaaaclon 
David Kaonady, Dlractor. 

Dapartaaoc of Wacar laaourcaa 
Karl Winkler. Departaant of Uatax Kaaouraaa 
Senator Alan Cranacon 
Senator Pace Wilson 
Congresaaan Caor|e Killar 
Congxessaan Vic raalo 
Congresaaan lobarc Hacaul 
Congrassaan Richard Labaan 
Congxessaan Tony Coalho 
Incaraatad paxciaa 



KLa.lJfiS 



?8) st^- 



t± 



^ 



|2» 



lob gohroadax 

aa of laolssMtioB 
2100 Cottava Kay, Rooa W-31SY 
■ snrsMnto, CA »St2S 

Dear Hr. tohroadari 

Dafaadan of aildllfa aobaita thla lattar co correct two ainor 
arrora oootsload la our Voveabar t, 1915 letter la responaa to tha 
Draft BnvlronaaDtal lapaot Itatsaeat and Bnvironaencal I^>act Report 
(DRXi/RZR) oo tha propoaad Coord ina tad Opwatioo Agraoaant ICOA) . 

Oa pa9a-2, tha word "ranawing* ehoald be replaced by tha correct word 
'raaovlog* oa lina Buabar 3 (down frca the top of the page). The ovarall . 

parpooa of that paragraph la to axpraas our concern chat raaoyloq tha J 

proaaat aoracorliB on oew water aarvloa oontractlog could facilitate J 

agrieultaral expanaloo which, in torn, ooold Jaopardise aany llatad . 
and oandidata spaoiaa ondar the fadaral Rodangarad Bpaclea Act. Many 

of thaaa apaoiaa ara alao liatad ondar California 'a endangered spaclaa i 

Uw«. - 

On pago-3, llaa aiHtoar 20, tha wox4 'aavlroaaaatal* Is mlsspalled as 
'aavireaal.* c 

two oorrvotioaa la tha appcopriata pobllo raoord. 

for fo«c aaalttAMM. 




[lohard tpotta 
California RapraaaBtaliwa 
Dafaadara of Nildllfa 



CALIFORNIA OFFtCi; MM ROSf OAlf WAY. SACRAMCNTO. CALIFORNIA 9M22 • (916) 442-6M6 
NATIONAL OFFICE: 1244 NtNITIINTM STRUT. NW« WASHINGTON. DC 2003* • 1202) 659^10 



115 



lAHe SH4SU e4¥£JflfS^^ 







2100 utf^ mt 



DMr ». Utniliri 









^S- 



taMflu. ti < r«i>l(, tiM Uk> l«Ml U )fiw«i *r*M «■ MklMrlit wm«»j 

«ll. tk. .Uht nHnttn fn I||VI t* ^ j y | rfi j ; ^g l J lwiH»Ti ^i^F^" 

Mm tk> Mntnctln if |kMt< tm pf '««H*Mi||^ir*"*tf^ <W ■>< • ' 
tnatirt tt CMr^wO «<&^ tka am, iWriaM t^M' tka <«•)•. Mtt 












«• r <IM<1« «■!> Mnm»», kit « * ittnct ■■< ta1< twrliu la t** irM. 

■-_;,>. W4 li awt f* Mm rt i»intlw « t*> ItU ^ic* m i> Mrcra fliMcKI itmt 
3iF%31jMl •!• *• 4Hwr •> ilMlit- TwiM a i4>< awu kw • tiiiiriaiit (fftct « 
I- -^fJiVX timmf^ tk» anifi mmV m* iImiM to omiikW ii 11^ •« am 




; 

I 



•ku u » Nil n •« to* M,t ikMrtki •«)«( if >ri ti«^tl» «m 

• Wftakv •« itM MS akMt kkH tthn Mn f ijliilii (m«m«-»<i» t 
ml *>■ IM fnt at t** IM tf feM«C;mi MM».M W I KMax 



••tnMUtlaa H tmir. *ta. <«"• NMlt kf Ort* ykkc* lai I 



;?5r- :H.:r*;r:-'txi" 



A 



National Audubon Society 



CAWBt »mm 



U.I- luraMa ft( lii 1—1 li 
2100 C*tia«* War, IBM l»-IUf 
toei ■■■!■. U •MU 



'n 




S' 


ei^^.- 






V 


































. J 



r^«* 



TfM BstiaBsl miufcM BMlaty ■ppr— Ut^a UkU hhiImIii t* Ma^at m Uw 
Draft fciTl rni aii t Al U^Mt tt^t— t/lpi rl , far tte 0«ir< !■■>■■ Ovw^tUa •« 
tba CMtral faiUf mjMt m* U« tuta Hata* rraiaal. 



Wa Mwwt ika taal •! aaar^laatlas avaratUaa •« i*a OMlral Tallay 
rro)aat (CTV) mut tte Kata Hatar rrajaat (■»). TteM t«» aalar ^»a«^^ 
• rataaa ar* Lat«mlata« la taraa at aatar aupvliaa aa« Uta '-f -- - - ttef kawa 
er«at*« aa CalLfanla'a •Mviraaaaat. Cii ^ n ltaa aa4 La^ •« aaar4Uatlaa 
twlMMa ite taa yrajMU teva latf ta laaff IsLaMLaa «M MMc^aat MsTllaia 
Lkat ara Mntrmrr ta aarti— a l allr md ■iwdiallf ■—■ aaiar raaauraa 
fl—iLa » . Tka i rnpaaaa aatLaa U a uaafvl vt«» U l^iail^ t^ aa^fta^at af 
our Mata'a LlAlta4 aatar aiv^lLaa. 

T^a yripaaaa aailaa la Ukia aaalyala aaatalaa aawaial atirtfeuiaa «U«li 
im<L4 tmL9 rrotMi Um «alta-har aalkMrT- Wa ii^iirt t^aa vravlaLaMi 
r«rtl«aiiarlr tlMaa aklak aawtll »r tka Lm» tAa CW ta urteUl^ 4al.ta aatar 
» f ii r *a aa aatacmiaatf kr t** ttata HBtar Maaaaraaa Oaatral 9mtr4. 

Ua ara aarr r aa nr aai. kawaaar. >*at Urn «raft tU/na «aM aat ipiifc »ltk 
clarltr M^ mint iiiaaam ta tka fLakariaa L^aatj Mr t*a llkalF l^iif 
of Fr«vt4laa aa aMlttaa*! 1,000.000 aara-faat •( aaUr ta Um MT aatf CW 
aarvtaa araaa. Ma ara »artlcuiarly iMii r aii tkal aMali Aalivarlaa aaul4 
roracloaa ipf i m iwlHaa ta aaaura a suaraataa^ aatav »^9if Car t*a faiaral 
aa4 atata watLa^ araaa ta t^ Caatral fallar. 



AMBUCAM OOMMrmO TO OOf^UVATtON 



It U alaar (raa mtr rarlaw. tkat a aajar Iac^Im for tte yrajaci 
avamara U caartfUtttlat tyar^ H aaa waaU to tba llfU^ af tte l«T« latarioc 
OayartaaM. ■a r a t ari iM aa aaw Cvr aatar aarrlaa. Ita taraa provlto ttot oaea 
cvr r aapaaalfcHltlaa far iaaUtalala« «alta aat^r ataniaria ba«« ba« 
aataklUkatf. tba aaratarlaa aauU W llfta«. Tbla faLlcr teelaloa mm 
aa ff ill by pa»araJ alkar rrortalou fartalntat ta tba afacatio^ at t^ 
cvr. mmm af abUb ara rafaraaaatf La tba biatarU*! aaaamta laa^ti^ a» ta Um 
I rapaaai aatLaa. Tar tba raeartf, tbaaa rrarlalaaa, by tbaa bacratarr CaaLl 
■■ •ma , iaa l aJa* yraf aala^ La«L«latiaa tai 

(1) Mtbarla* tba CW u aaat atata CtelUI ■liliiOi aa apyraaai by t^ 
■aaratary m % laa iilaa >!■ haaU . . . 

(2> Butbarlaa tba ■aaratary ta raLaaata tba CaMn Coata CmmI . . . 

(»> mmA tba CTV alMiaiaa t« rravUa Car CUb b« vlUliCa 

(«) Mitbarlaa rr«vlalM aC a giarMlaat wtar ai^vly tb OMtrat taller 
■atUMl MUlLCa baCivab . . . 

Iha valiay AaaLalaM U CaaiM tba aaar<lMtai a^arvttaaa fropaMl «■ aatr 
tba CirM Itaa U • *af ar twra Craa tba kimd H ta^rabaoalva vatar raMwff«a 
» 1 — t at w mmmi a^ U tba trntnu t* aur traataat c««aear«a abawt t 



m «laat r aa wltb tba ata t mm » tbat tba UPii"t rrv^Mta tba UtarMta 
•t batb peajaata ablU aaaiUt miar-raUtatf amlraaMMtal 
« ^ f — Ibtiltlaa. Tba aaiy aiMb raayeaalbiHttaa aia^uataly aMrw*a« 
partala ta ■ m- Mia l i ■■■ Jaa^U «alta. ya ballava tba yropaaa* actiaa 
aayU bawkCU tba «alta hit at tba i i mii aC uyatraaM fUbacr raluaa. 



Ua kallaaa tba «iaaaaalM w4 ' i ii i rtab leaaai 

t« tbaaa balaacMrari Clafc nmm. Tba tfymaMl* aninia mt af CW facLlLtiaa 
aaaU aali r«a>tlt La sLcftLrieaat riuaUkatlaiM La floaa ^tt waiar 
ti^iritMr«a La i^atraaa r aiifcia af tka iiTM—t* . tmmcicmt. ^ Trlalty 
Urara. tfUtar wm4 ayrlat RM CblaaoK SalMa hava aLraaay inirlT---t 
alcalCiaaat 4a«lLaaa ladar tba yraa^t atanUr«a. OaatakllUL^ 

■ a^ fl«« r a t i a aa mag aall «aatrey tbaaa nii it r«puLatiau, 



116 



■r. lobM^ •chroster 
■ovfcw IS. ItW 



Th« ttwiterta yrBT«««< 1* tte aMirai* mhU ycwtwt fUk U ito telfca tari 
•t tlM ««>wMi of (Lsh p«f«iatlaa« at ip — Lag ■!!«■ iq^atcMMt. It la 
lBcerr«ct f ataia ttet rralMii** ataMlw^ Matala^ U ttAlMt A •*• 
■urrtelaailjr rirwritiiif 1-i ta prvtaai <Lah raMucMa Unu«taut tto 
wallar. Onlr Uw««k laatraaa flaw rtaa<ir*a ami taa>Taliira aaatral 
protraM aaa uratraaM <Lab raaawra— k* atevutalr »««t«ata«. 

Ua itro^lr baltawa ttat aliUatlaa tlawiaal^a a>a»l< »• aivaMtetf ta 
IncluAa tba a44ittaa af ■ilil»U~la«al UUfeM U autUt atruaUtraa at 
Clair matl* m^ Hiaata Baaa ta haly eaatral tka aatlalyatad taarantMra 
■bilU at tha prafiaa< frajaat. 

raca t-?. CUBtUtlva '-j----- 

ua atrM la rriMLyLa tkat tka prafiaa* t^riiaiat aaa ha li— li w il • llal 

In a chala of avanta tJMt cauU laai ia athar aciioM ttet smU teaa 

■ lioiClcaBt aarlr«Baatal lavMta. far Uda raaaaa w balUm tJw «r«(k 
III Biat anairu Mi fraUat atet ••» af tte a(««Utt«a m* laB ^ taf 

la^acta couU ba. 

It wa accavt (or tte aate of miwaal tlMt 1.000,000 aara-eoat aC aotar 
can ba M4a anllakia (raa t^ CYT thrau«k f>ar<taata< apart lai md 
Urtii« of ttaa kaeratarlal aantarliM. tha aaa a< tkla aatar aaaU kavo 
profot^ laracta «« tte aatural liiiii»a la Cailfarala. 
laoda cauU to coayactaO t» aarlealUira tfeat aHmstIr < 

■ tata ltat«« thraatw< mO w»<aaoari< ayaalaa. 
•ddltlaftal IrrltatlM awwlr ^uallflao. la aur vlav, aa i 
Indlract Upaet ■aalHii by tba OatlaMl fc rtri— ■■*■! »allcr Aat. 
kind or atalysU tea m Itirtaat b—rt— aa tba avwmU aaalaatUa a< tto 
projact. 

la pravloualr atatai. «• alaa ara Oaaolf n a « icma< ttot aaaa tto wn a ao t aJ 
1.000.000 aara-Caat U aaaalttatf ta tto M* aa* IrrUatara wltbla tto 
Cantral Yailar. llttU If ay Buaraataai yimld awU to avalUbla ta 
miffort vlAtarlj« mtarfaal ar««a «• ataU amd faAanl rafufta Ua«a vltkto 
tto affacta« araa. Ttoaa rafuftaa ara tot a r taat a< tto iw «l — « 
raaourca wblch aslata* friar ta liailipaiit af tto CW aatf tto Itotf 
cMvaralaa mOak (allaaai. 

rata 9* 

m ara toU tbat tto prajiaii aatlaa n aaUaa aMad lar lr ito H li I 

pratactloa w aa ovarall baaU a^ ttot U aav vrajaat CaallitlM an 
built ttoy will tova ttolr e«a aarrliyaalai toaitotota. Ha tollaaa U U 
lAcooalataBt with aowd raaau r aa aanatawat ta f oa ty a ttot Ua« ^ 
aoalrai' to oa^ Utar teta aa a yraiaa t br grajaat baaU. Tbla aatlaa 
la. U a varr raal aanaa. tto faua4atlaa ahieb aakaa auab futara yrajaata 
poaaibla. It ia tora ttot ttoaa braa< laaaaa a( awaUtlva i^toU iftwU 




Natural Resources l3e{enaeGxukctl,inc^i 



U ai^Hrr. aa toilava tto «raft lU la aarlaualp tofUlant la cartaia bay 
araaa. It aboaU to wiiMraaa mtt mm*U ta rrwlAa tto public «« 
lailllia Mtori a taaauraa Car ^Ai^ iatalllt>Bt Oacialaaa on thia varr 
aiialfUaat p i afiiai. tbaafc jw» far yaar aaaaUaratlaa af our «1«m. 

■iacaraij. 



OMUL usua 



•^ tB*anr rrtExy-.rb- ■ 



>■« raaa<>aaaa.a.« -*--^ ,.... . ^a- i*%«, , ;>, .....j/,i*Lj«.. j 















:>>; 




D.S. iux*A« of ■■n1>M»1«i ' • 
2100 CatU9a lt>r, loca »-Ult 
SacTUMU, ollformK »5l25-ln».^^ 

DMT llr ar iiiImi ' t -''.^ r 

taciomma mzm a» aa^HM> «( fat* MtaM^ •■•■■«>•■• ■ < ■••^'yti-^-rr^ M 

omtmM couBoll. b la ill»«iQ»— <l ia'tiM v ii i t». «• **'*'J^y!Z^^'^Ji 
tbat tlu Draft Bnriji.iiMl il Ik(isa« >tauaaBt/M«axt ka* ^'^^l\{f^£r 
ii«bar of daf lolaaolaa , oblsh auat ba oorzaatsd It tlia ClliaX -^ijs'^ 
docuaaat la to ocB^l 
Mt. 



naBk yoB for 



(»r »lU>.Wia I>at4a«al. ■snn'Mi^ta) ^>J4o^^;n^ w^' J 









•"' ! 'rr;^??;^ 










■:^tS??Si;' 







t rata Wllaaa 
tto totorabU Oaaria Ullar 
Karl Maklar. Davartaaat wl Hatar to aaa w ta 
Jls tolaritt. u.l.r.u.l. 
CalKacmla Uatarfaal AaaaaUtlaa 
■atarai I 
rifiili r of WlUllfa 



Natural Resourc^Defense Council, Inc. 

t5 KIAINV ITiaiT 
■ AN VIANCISCO. CALIVOBMIA 94 I oS 

4i9 4ii-6s6i 



• ■I* aaw vaai *«■■«■. ■.■ 

•VtTl ■•• 
«A*BI»«T«H, V.G. •••a§ 

■•> Tlf-f laa 



nmwmw or m imtubal kuooicbs Deraisi council 

CM rm DKATT BMViaomnnAL impact STUmiElfT/RXPOItT 
COOKDIIUiTID OPEKATIQM ACKZEKEirT 



Subaittad Byi 



Laura B. King 
HamlltOQ Candaa 



Ntm tmgltmi Ofm: ly> hmtom fan m 






117 



coKKzifT* or Tsi UTmu. Ruooacia urmi codwcil 
ov THi OULIT nnnnoiQiiitTU. mPAcr rrAmmrr/UKiBi 



X. Introduction 

Thos* I iMBiiif OA tfta Draft ■iiiliia— in ■! 
Stac«a«nt/ll«port (h*r«iaatt«r 'Dvmtt UJ*), CoerdljiAt«d aparmciaa 
A9ro«a*Dt. ar* auAAittad on b«bal( of tiM teturml Ko*oaxvio« 
OofoiiM Counoll (nUK|. nmc la a national, aoB-pxvflt 
anvlronaantal or^anliatloa wltA offloaa la lav York, Maabia^toa. 
O.C., and San Pranolaoo. KXOC haa orar fto.ooo aaatoar* and 
contrlbutora natloavida, atooat 10,000 of ab^ raalda la 
California, nuic raoantlr publlabad a raport oa fadaral Mtar 
pricing pollclaa la taa Cantral Vallay riojaot, aatltlad Turn lag 
Jff tha Tap on radaral Watar Buaatdlaa . and la ourraatly angagad 
in litigation ovar taa handling of agrloultural drainaga vatar 
froa tha Cantral Vallay rrojaot at tha Kaataxaan Klldllfa (atuga. 

Tha propoaad Coordlnatad Oparatlon lijiataain (OQA) 
rapraaanta a aajor atap forvard la tha battla to protaeC 
Callromla'a vatar guallty, la that tha fadaral govamaant baa 
•graad for tha flrat tlaa la tha COk to aaat atata vatar quality 
■tandarda for tha Saa Franolaoo Bay Dalta. A« n^Mnaa raporta 
nava docuaantad, vatar quality la tha lay Dalta faaaa critical 
Ulraata and la In dlra naad of protaotloa. Ba ai« tharatota 
plaaaad that tha fadaral govai iiaaiit haa agraad ta adhara to tha 
■tata'a vatar quality ataadarda. ■owwar, va bava aararal 
concama about tha COft and about tba Dvaft US oa tha COA. plrat. 



wa ara concamad that tha aaacutlon of tha CO* vlll raault In tha 
algnlng of aany aav ooatracjta tor dallvary of cantral Vallay 
Prejaot (CW) aatar, »*fc«T that vatar unavallabla for othar 
■ nil II iinaanTanr baaaflolal purpoaaa. Oapandlng on tha aaount of 
vatar oontraotad by tha kiraau of Kaclaaatloo, llttla It any vatar 
vlll laaalii avallabla for vlldllta rafugaa, vhara It la badly 
naadad. Ika Draft lu dsaa oot addraaa thla llkaly lapaot of tha 
•IgnlBf of tha oak. faooad, u cba Draft MIM adalta, aoaa advaraa 
anvliimaanTal affaota ara lUuly ta raault froa oparatloa of tha 
cvp In tba — 'w*^'- naartail to aaat Dalta vatar quality atandarda. 
Howavar, tha Draft U* falla ta propoaa altlgatlon aaaauraa vblch 
Bight allavlata auca advaraa lapaota. Ttilrd, tha Draft 111 doaa 
not addraaa tha daflotaaclaa of tha axlatlag •Daclatoa 14t5' Dalta 
vatar quality ataadarda aad falla to ccnaldar vhathar tba CO* 
ahould provlda for fadaral cooparatlon ahould tha axlatlng atata 
atandarda ba aodlflad. Onlaaa thaaa daflclanclaa ara corractad In 
tba Final III, va ballava that tha doouaant vlll ba fundaaantally 
Inadaquata. 



II 



lapact of tha CO* oa Watar >YatlabllltY for rlah 

anT vlUlUa ilahlUt 



In lt7l, Intarlor laijialaiy andrua aatabllahad a aoratorlua 
on tha algalag of nav contraota for CTV vatar dallvarlaa by tha 
luraau of laolaaatlca pandlng raaolutloa of tha 00*. Onca tha CO* 
baa baaa axaoutad, thla aoratorlua la llkaly to ba llftad, and tba 
luraau vlll ba fraa ta alga aav oontraota for watar dallvarlaa. 
*a tha Draft HI atataa. 



'Attar tha pnpoaad agraaaant la axacutad, tba 
Buraau Intanda to aa* tba aacratary of tha 
Intarlor to lift tha aoratorlua, tbua allowlag 
tha luraau to antar Into nagotlatlooa tor 
poaalbla contracta tor davalopaant of tha 
^incoaalttad vatar aupply of tha CVF. nla 
uncoaalttad supply la aatlaatad at about 
ona alllloa acra-taat annually.* (Draft 111, p. 



•I 



whlla tba Draft Ml» thaa aAtlta that tha aoratarla oa nav 
contracta vlll ba llftad aftar tha 00* la algaad. It doaa wot 
•nalyia tha aaviroaaaatal iiiaiiiijiiaiiiiaa of thia dlxaot raault of 
tba CO*. 

That tha algalag of ooatracta for aa addltloaal oaa Blllloa 
acra-taat annually of vatar dallvarlaa vlll hava algnlfloaat 
•nvlronaantal nna aa qn a an aa oanaot ba dlapotad. Ba ara 
particularly ccnoamad about tha lapaata that tha algalag of au<A 
contracta would bava oa watlaada habitat, both by vlrtna of 
pracludlng tha provlaloa of vatar to vatlanda araaa, and by virtoa 
of an<x)uraglng furthar oonraralon of vatlanda to agrloultural 
davalopaant. Vatlanda habitat la California la la orltloal naad 
at fraah vatar auppllaa. Tha axlatlag vatlaada habitat la uaad by 
to paroant of tha Pacific flyvay vatarfovl populatloa.^ of tba 
originally flva alllloa aoraa of vatlanda la California, thara 
raaaln now oaly 490,000 aaraa.' Tba callforala Vatarfowl 



^Mona I. Dannla and Mary Laural Harcua, atatua and Tranda of 
Calltomla Watlanda . praparad tor tha California kaaaakly 
Raaourcaa lii l ii laalttaa oa Itatua and Tranda, p. Till (ltt4). 



*aaoaUtlaa aatiaataa that two-thlrda of tha aarahaa raaalalng la 
tha Cantral vallay oould ba loat If watar la act aat aalda tor 
thalr praaarvatloa.) Tlia 0.1. rlah and Vlldllfa larrlca baa 
111 laaaiii l i fl that appnxlaataly 900,000 acra-taat, or an aaouat 
aqual ta half of tha f lining nnonaalttad ylald froa tha Cantral 
Vallay Projaot, ba aada avallabla for praaarratlon of axlatlag 
vatlaada.* 

n>a watlaada* aaad tor fraah watar haa baocaa avaa aora acuta 
In tha laat fav yaara, aa tha ortala at laataraao haa aada olaar 
that agrloutttral dralaaga watar la fraquantly too toxic to una in 
watlanda araaa aad oaaast ba aubatltutad for fraah watar. Tba 
CallfomU Dapartaaat of rlah and Oaaa and tha D.I. rlah and 
midilfa larvloa raoaatly ]olnad la raquaatiag froa tha luraau 
lf4,«00 aora-faat of fraah watar ta halp daal with tha dralaaga 
vatar problaa ia tha araaalaada araa alona.> 

Tba Draft til doaa net argua that tha oontraoting of n— 
vatar dallvarlaa will not bava algaiflcant aavlronaantal iapaota. 
••«*". It avolda tha n a o aaai r y job of Idantifying thoaa ligMota 
by argaiag that noa Iapaota oanaot ba dlraetly attrlbutabla t« 
tha 00*1 



3ld. 



'Lattar froa Oaa Otapla, Callfoniia Katarfowl *aaoalatloa, ta 
lanator Jaaaa nociura, datad Ootabar 7, l«t9. 

*D.I. rlah and alldllfa larvloa, propoaad riab and lllldllfa 
Coordiaatlon act laport oa tba Coordlnatad Oparatlon *araaaant 
pp. 9-« (laptaabar 29, 1M«| . 

^Lattar froa Dlraotor, California Dapartaaat of rlah and Oaaa 
and Ucbard J. Ryabak, lagional Dlraotor, 0.1. rlah and midilfa 
larvloa, to David louaton, lagional Dlraotor, luraau of 
•aelaaatloa, datad lay 14, lti9. 



118 



*{T]ha coniwctlon batiraan tiM Ooordlnat*d 
Operation ^^^'••■•nt and any potantlal d«w oontraots 
la tanuoua. Plrat, thm Coordinated Oparatlon 
A^raaaant la not a praraqulalca to auota oontracta; 
naw Cantral Vallay Projact oontracta aay ba algnad 
with or without tha Coordlaatad Opuratlog JKrraa««nt.' 
(Draft IIS, p. 1«) 

Tbla arvumant baa a mmbar of flaws. h» wo will daaenatrata 

balow, tha signing of naw oootraota will bs • dlr^otly 

attrihutahla rssult of ths cok, and ths lapaota of such oontrsots 

■uat tharotora bo ooosldorsd in thl« BU. 

Tha Counoll on Bmrli niMiiitaJ. Qa*lity*a (CSQ) rvgulatlona 

lavlsaantlng tha K^^onal Knylmfwantal Volley Act (VBPA) 

sxplloitly raqulro that an action's oaalatlva lapacts and 

Indlroet affoeta ba asaaasad In tha anvlraiM«nt*l l^aot statwint 

on that aotloo. Tha signing of tmt oontrsots tor iMtsr dsllvsrlaa 

olaarly roproaants both. Tha daflaitlon of SMVliia»aiita) of foot 

undar tha CXQ rogulatloos Inoludos oornlatlvs Ispaota. 40 C.P.X. 

■aa. 1501. •(b). 'Oanlatlva Ij^aot* Is dafiaad as 

*tha lapaot on tha anvlronaant whloh rasults 
froa tha incraaantal ljq>act of tha action whan 
addad to othar paat, praaant, and raasonably 
foraaaaabla futura actions raqardlaaa of what 
agancy (Padaral or non-Padaral) or parson ondor- 
taXaa auch othar actlona. cuaoUatlva iapacta 
can raault froa individually minor but oollsotiwsly 
significant actions taking plaoo ovar a p«rlod of 
tlJM.* 40 C.P.B. «*c. 150t.7. 

Jka tha Draft 1X8 Itaalf ackaowladgM, ths >ar*sa is plaBniag to 

raquost that tha Moratorlun on naw oontxmoto bs littad and will 

saok contracts for dAlivarlas of watar «p to oas million mar^-fut 

psr yaar. Obviously this is a foranaoabla tvtura oetioni nPA 

tharsforo raqulrss that its Qenaaguaaaas ba addraasad la this 

IIS. 



ma CIQ ragulatioas similarly raquira that an action 'a 

ialiract sffaots ba snalyiad In an l». 40 c.r.l. Sac. 150«.t(bj. 

Indiroot sffaots ara daflnad as sffacts 

*wbich ara oausad by tha action and ara latar 
in tlaa or farthar ramovad In dlstanoa, but 
ara rsasonably foraaaaabla.* Id. 

As wa bavs notad aarllar, tba Draft Bio arguaa that auch 
indiract or onaulatlva aCfaots may ba Ignorad in this IIS booauaa 
tha rolationahlp batwaaa tba COA and tha signing of naw contract* 
is •taauoua." In light of ths fast that tha •aoratary satabliahad 
• moratorium prscludiag tha aigniag of naw contracts until tha COA 
was aatacutad, and in light of ths statanant in tha BIS that tha 
Buxaau iatands to sssk tha signing of nsw oontraots aftar tha coA 
is asaoutad, tba ralatlonship appaars to us to ba vary diract and 
not tanoous at all. «hila tha Draft lit statas that naw oontracta 
may ba signad without tba CO* (Draft lU. p. II), in fact tba 
Buraau has not signad and will not. sign long-tarm oontracta until 
tha COA baa baan amaoutad. It is tbarafora aaoaasary and 
appropriata to analyia tba iapaota of aigning naw oontracta in tb« 
BXi on ths COA. 

In arguing that tba oeansotion batwaaa tba COA and naw 

oontnota i« tanaooa, tba US also implias that ths division of 

watar ba tw aan tha stata and fadaral gova ra mants is irrolavant to 

tha quaatioa of bow aneli watar is availabla for naw oontracta. 

"Saooad. S>hlhit b-3 la Includad in tha agraaaant 
■ora to aatabliah tba positions of aach party with 
raspaot to tha rights of tba otbar party tb«n to 
indioata a phyaical praaanca of oontractabla watar. 
■batsvar watar ia phyalcally availabla in tha 
•yatam Is avallahla ragardlaas of tha Agraamant.' 
(Draft US, p. IB) 



This statamant is mislaadlng at bast. Hot only doaa tha signing 

of tha COA aziabla tha buraau to bagia oontnoting for naw watar 

dallvariaa. but ths alloeatlon batwaaa tba atsta and tba fadaral 

govammaota baa a diract affsct on how modi watar tha Buraan bas 

availabia to oontraot with agrioolCoral and ■onicipal osara and 

bow much tha Buraau may maha availabia for watlaads. It, tor 

ajtampls, ths Buraau's ahara of raapcnsiblllty wbaa ai^ort wmtar la 

availabia wars 4ft paroaot as opposad to tha SS paroant undar 

consldaratloa, than tha Buraau would bava avan laaa watar to aot 

aaida for watlands. If ths Buraau* a ahara inoraaaad to S5 

parcant, than tha Buraau would bava mora watar availabia to aaat 

agricultural and nunicipal watar d— anda aa wall as to aupply 

fraah watar to watlands. Ihua tha aatabliafamaat of aharaa Itaalf 

datsrainaa tha amount of watar availabia to tha Buraau to aaat 

varioua watar n aad a , including that of watlands habitat, and ths 

lapacta of tha allocation ot Btata and tndarml aharaa on watlands 

habitat Bust tbarafora ba oonsldsrad ia this tlB. 

Tba Draft BIS alao arguaa that it aaad aot ooiMldar ths 

anvironmantal affacta of signing maw ooBtraots at thin point 

bacauaa 

"futura actlona bayond this Agraaaant would ba 
nacasaary and would ragvira anvironmantal doeu- 
mantation and mitigation.* (Draft US, paga S-T) 

*[l]ach contract would ba a aaparats and Indspan- 
dant action aubjact to atudias on wstsr availa* 
blllty and anvi rnn aa n tal ii^act.* (Draft BIS, p. IS) 

Mhila wa agraa that aubaaquant anvlrrwantil doounantstlon of tha 

affacta ot aigning Individual oontracta and ragional atfaets of 

signing larga mtmbara of oootracta auat ba praparad, BBPA also 



raquiraa an aganoy to analyta tha offsets of sooh actions In sua 

batc»n any ot tba individual aoticns ara inltiatad. Mhan, for 

•xa^la, tba Dapartaant of tba Intarior attaaptad to aatabliah an 

indastrlal watar narkating program tor tha allooation ot watar 

soppliaa troa a fadaral raaarvoir, tha D.S. Court of Appaala rulad 

that tba Dsparta silt waa raqulrad to prapara an US on tha 

ooaaaquaaoaa ot tha p r ogran aa a nhola, and that praparation of an 

UB oa aa individual ooatraot waa iaadaquata. Aa tha dacision 

polntad oat, 

'Courts bava aoknowladgad and maiatalnad a 
distinction batwaan an KIB for an ovarall plan 
and an WIB for aa individual laaaa, llcanaa 
or ooatract issuad pursuant to tha plan . * 
tnvironmantal Pafansa Fund v. Andrus . 13 IRC 
at 1375, 1377 (1979) . 

■ilia tba Draft US auggasts that thara ia praaantly no plan for 

tba aigning of naw oontracta, it doaa aeta that tha Buraau bap 

■totura ooanltaants* to daiivar approxlmataly aavan alllion acra- 

taat par yaar (Oratt BIS, p. ••) , or naarly ana nlllion acra-faat 

Bora than it is «aiivaring at pr aa ant, which indicataa that tha 

Buraau doaa bava a plan and that tha plan ia to oontraot aoat oi 

tba raaalnlng CVP watar to mnaiolpal and agricultural uaara. As 

tha Binth Circuit has fouad. It is not naoassary for all tha 

■paolflo datalls of a plan to ba known in ordar to conduct an 

assaasaant of its aavironaantal affacta: 

*niat tha axaot typa of davalopaant la not known 
is not an aaccuaa for failing to fila an impact 
statamant at all. Uncartainty about tha paca and 
diraction of davalopaant aaraly auggaats tba naad 
for axploring in tha llS/IZIt altamatlva acanarioa 
baaad on thaaa axtamal contlnganciaa. Drafting 
an BI8/EIB nacaaaarily involvaa soma dagraa of 
feracaatlng.* City of Davia v. Colaaan . 521 F. 2d 



119 



««l, •?« (ftth Clr. «Ti). «twt«d U invii wiit^l 
E»fMf fund y, Jlndrua , IJ KSC at l}7«. 

1 prapuntlea of ui Kit an i 

i.vttr fyBtMB «at«r ■urlutlog, vbloh 

•pp«ar« to b« r«lftt«d to tho ^uotloa of mw oontnoto to bo 

■Igrtod ttrtLor tbo OOA lo oxoovtod. ftaaod oti our rovlow of tho 

scoping Xmum tepert for tU* KU. bowww. It will oat fulfill 

tba Bur*«u*a obllgatlena ^tfor VXPA bMsanoo it loolu at tha 

• ffaota of algning mm oootraota in only ana part of tha cvr. 

Hhat la noodod rathar la a CVy-^14a aaooaanoDt of tha ii^oota of 

alftilng kany now oantr*ot«, aa aanaa^aant vbloli ahould torn IfMflwf^il 

la tha IIS on tha CO&. 

■ban SooratAry Andnu iaaoad kla teoUtan ant«bllahla9 tha 

■oratorlta on tha al«nin« of mm aantT«cta la tha Oantr«l Vallay 

»ro]aot, ha atlpulatod that tha nontorlub would not ba llftod 

until tha OU had boon algaad ravpootlag wtMf vatar athndarda. 

utd n i i ^ l ttod tha Oapartaant to taJOag Mnmrml aotiona 

alaultaanoualy vlth tha algning of tha OOA in ordar to protnot 

flah and wlldllfa. Aaong thaaa vara aotlona to glva agu&l 

oonaldoratloB to flah and wlldllfa purpoaaa In tho ilai ■! iifiiii and 

allocation of any aaw (poot-ltTi) CVP untax nuppllaa. •ooratarlal 

Daclalon nomm a n t datad nirrmr U, lt7t. Claarly SMiratary 

Jkndrua aav tho signing of tho COk. whlob vaa to froa tha Buraan to 

•Ign naw oontrmcta for vator dallvnrlaa, aa hoTlng an Impact on 

flah and vlldllfa maottrona and tharafora requiring addltl<»al 

aotlona on tha part of tho Oapartaant and tha luraau to nltlgata 

thoaa Inpaota. Hm KIS ahould oanaldar thaao Inpaota and ahould 



an sltnmativa In lAlefe pvntootlon of flab and vlldllfa ii 
glvan aqual ooaaldaratlon to aatorlng Into now oentraota for watar 
dallvorloo- 

III. Ttta Lack of Mitigation Mnasuraa 

km tha Draft niM Oiteltn, tha axooutlon of tha OOA vlll bav* 
anni advnma aiiil i wanTal l^paota, baoauaa tha fadoral 
gowarr— nt'a aa— Ifnant to noot atoto vator ^lallty otandarda nay 
naan that fadoml ranorvolr* vlll bam to bo drawn down furthor ir. 
dry ynnrs, wblob in tom vlll ntlno 4avnatraan rlvor taaporaturaa . 
hM a r— ult, flab brooding potontlal vlll ba roduoad. For 
axaapla, tha Draft lis aatlnatoa that Incranantal nortallty of 
Cblnook anlnon In tha Soonnanto Uvnr would Incroaoo during dr>- 
yoara by S-30 poroont at oorrant oporatlon lovola, and by 13-70 
porosBt at tho oporatlon lovnl ■aoiniad In tho yoar 3000, with tha 
oxooutlon of tha COk. Draft KU, pp. 75, 7C. Tho o.s. Piab and 
■lldllfo Sorvloo la wory oaBoaraad about tho flohory Inpact of 
algning tha OQft, and otatad In Ito draft raport on tho OOA that 
■axtlrpatloa of tho [vlntor^run anlnon) raoo lo not Inconoolvabla" 
aa a noolt of oparatlona nador tha COk during dry yaarw.^ 
alvon tho oorlOQS aatur* of thooo potontlal l^Mota, tha IIS nuac 
dloooao mitigation naaaiiiaa that would bolp nllawlato tho Ij^actt 
40 C.P.B. too. ISOa. 14(f). no laplaiMatlng rogulatlana for VIPA 
giwo ft iyaolflo daflaltlon (or mltlgatloa vhlob Inoludaa: 



*0.S. Plnh and Vlldllfa Sorvloo, rropoaod riab and wildlif* 
Coordination hot loport on tha ooordlnatod oporatlon Agroa«ant. 
p. i (Saptao^or 25. IfIS). 



*(a] Avoiding tha l^ot altogothor by not taking 
a oartaln action or parto of an aotlon. 

(b) Hlnlnlilng l^ota by Halting tha dogma or 
aagnltuda of tha aotlon and Ito iaploBantntlon. 

(o) Eaotlfylng tho l^>aot by ropalrlng. robabllltatlng. 
or raatorlng tho aftootod anvlronMuit. 

(d) Kod u ol n g or allalnatlng tha Ij^aot ovar tiaa by 
praaarvatlon and aalatonanoa oporatloaa during tha Ufa 
of tha action. 

(a) Oonponaatlng for tha l^>aot by roplacing ox 
providing aubotituto rooourooa or anvlrannanta.* 40 
C.P.I. Soo. 1501.30. 

Tha Draft 1X1 falls to propooo, hovavar« Baftouroa vhlob would 

•coonpllah any of thooo purpooaa, auggoatlng inatoad that aoclstlng 

law* and rogulatlona and futura otx^loa will provlda adoquato 

mitigation (Draft IIS, p. tfl) . Ybla approaoh dooa not aaot tho 

roqulraaonta of nPA. 



IV. Tha Inadaquacv of prooont lay Dalta liatar Quality Stondarda 

Hhlla tha CQA would oo^alt tha fadaral govamaant to 
providing anougb watar to aoat tha atata Dalta wator quality 
atandarda. knnm aa tha "Dooiaion 14SS* atandarda, It la wldaly 
bollovod that thaoa atandardo do not provida suffioiant protootion 
to tha Dalta, and tha Stata Natar laaourooa Control board baa 
■nnouncod ita Intantion to ra-oaaaina tha aaieting atandarda 
ahortly and oonaldar aatabliahing now, aoro atrlngant atandarda. 
Ha conaidar tha fallura of tha COA to aako provlaion for adharlng 
to atrictar atandarda a aajor ahortoonlng of that agraaaant. Tha 
BIS on tha COA nuat addroaa thia laaua, aithar by oonaidarlnq ar 
■ Itamatlva action in which tha COA would allow for ooapllanca 



with strlotor otandarda or by aaooaolng tho oonooquancaa of tha 
failoro of tho fodoral y w aii^aiit to moot otrlotor atandarda 
•hottld tbay ba adoptad. Qila aaalyaU ahould a^lrooa tha quoatlon 
of tha taroan of Aaolaaatloa ' a ability to naot any now standaz^a 
that Might bo ootabllahad If it hao already oontraotad away all 
tha a rtrtltlnn a l watar that baa boon aada availabla ui^ar tho COA. 

V. Conolna|on 

It nat bo rMognUad that tha COA. whlla In ocm roopacta « 
■tap forward for tha anvlrotaaot, also haa potantlally aarlous 
laplioatlana for tho aawlroBMat. Bocauaa tha Draft III largaly 
owarlooka tha potantlally nagativa oonaaquanooa of tha COA, »• 
balloTo that tha Draft KU dooo not aaat tha baalo roqulroaanta of 
mPA. and org* tha kiraaa and tha Dapartaant of Vatar laaourcaa t: 
i abova In tha Pinal EIS. 



120 




'>ovaBb«r 12» 



:0b ;achro*dar 

^^r««tt of RcciftBAtion 

500 Cotts«a ««y. Rooa 11-2137 
.«cr>a«nto, Ca. 9562) 

^«rl «LnkUr 






<fifiii^C^>«?o~ 



:*crmA«to Ca. 95616 

^•i dEIR/KIS for tha ooordinatad op«r«tLn< acr«*aMt for th« Cantrml 
vallay Frojaot and in* CalifomLa tfatar Projact 

:.«ar SLra, 

«a appraclata thia opportunity to eo—it oo tha COA. Tha Sacrttaanto 

^Ivar Praaorvation truat (tha Truat) la a prlvata non-profit ornnlaatlon 

coneamad slth conaanratlon laauaa ea tha &aoraaanto Rivar and In Ita 

■atarahad. 

'.•\9 Truat aupporta tha davalopaant of th* COA. Only vlthooordlnatad 

^paratlon can Callfomla'a vatar projacta provida tha aaxlaua bantflt 

for Callfomia*a divaraa aatar naada. 

anfortunataiy tha COA laavaa opan aaTcr&l avanuaa of daatmotlon 
for tha natural raaouroaa of tha Sa«r*Banta Vallay. Tha final 
£tR/BIS ahouid addraaa tha folloslnt e«ncama and tha COA ahDuld 
aa aodifiad appropriataly. 

Taaparatura offacta In tha Saoraaanto RlTar and Chlnoalt Salaon 
populatlona. Tha d£IR/BIS Idantlfiaa tha llkolLhood of lathAlly 
•arm vatar durlnc aitraaaly dry yaarv. Tha ohinook aalaon population 
la daparaaaad far baXo« hiatorical lavala. larcoly froa tha affaeta of 
tha CVP and tha CMP. ProTlaiona ahottl4 ha aada in tba COA to altl<at« 
«calnat auch haatlnc affaota. 

«at«r auppliaa for Saoraavto Vallay alldllfa Rafufaa. Tha vatar naads 
of vLldlifa dapondant od thaaa rafucaa hava baan naclaotad In raoont 
yaara. Tha COA ahouid opacify adaquata ■Inlwia flows for tha rafu<aa 
and aat a ataadmrd for futura projaota. •» r- "... 

idditional aasurmnoaa of vmtar quality for tha lay and Oalta. 
:ha COA ahouid Inoluda aaauranoaa by both partiaa that thay vlll ablda 
by atriotar «atar quality atandarda if thaaa ar« datarminad oao- 
• ■Mr>. Tha coaaltaaDta to lay and OaXth .watar quality aheiOd ba 



PM^ 2 lOQl 

novaabar 12, 196) c3 

Saorasanto Kivar Praaanratlon Truat coaaanta on tha dSZR/^lS for tha COA 



Indafioita. 

Finally tha hiatorfpaof NBPA and CIOA indicata that an EIRAtd ahouid 
contain an anlyala of an anvironaantally prafarrad* option. Thia 
option aajtiaiftaa anrironaantal banaflt. No auch altaaativo la 
coniidorad in tha OKIR^Ifli ona ahouid ba. 

Ma would appraaiata it if you could aand copiaa of futura aailinca 
on thia aattar to aaeh of on* officaa. 

Saoraaant Rivar Praaarvation Truat 
909 12th St. #207 
Saoraaanta, Ca. 9581% 

and 

;iacraaanto Rivar Praaarvation Truat 

706 Charry St. 

Chico. Ca. 95*26 



Th«nk You 
dinoaraly* 



^^^ 



"Q!^ 



J la rott.r 
SMrvUry .f UM Tnilt 



CC: IMtrMU* tuWtt 



121 



I 



30 
United States Department of the Int 

BUREAU OF RECLAMATION 

SAN rCLIPE DIVISION CVP CONSTKUCTION OFFICE 
FO BOX *T 

CILHOT CALIFORNIA IMII-OMT 

JAN 2 4 1986 



^/•H I 7 1366 


"^1 i-.'.-v 


7x.\ 


^ ^--ffrl 


1 r-/ 1 






f 




1 




I 













KtiEKTv srco-i2L 

500.- 



To: Raglonal Dlfvccac. SacraasBto 

Actot rtr-'»o 

Ixami Projact Coutrucclon EnglB««r. Cllrey 

Subjactt CaviTonaancal lapact 3ta(«B«nc/eiivlrena*Mcsl Ispact laport 

for th* Coordlnatad Op«taclOtt A4r««BaBt — San rallpa Dlvlalon — 
Caocral Vallar Ptojacc 

Tltla la to cvtpoaaa to yQ<it January 16. 1968 •aaotaiulua. Ua have tba 
fslloMlng covBaota on cha aubjaec raporti 

1. TAa Kapa on pai* 1 and pa|a 1 of Appandlx do not dallnaaca 
tha Sao PalLpa Pcojacc. CSaa ancloaad map 'Kajor Paatucaa of 
tha SUr and CVP") 

2. On paga 6«. Tabla 9. Cha Haxikua Cnctclasanc fet tha San Pallpa 
Unit Bbould ba 116,000 acra-faac aod not 196.300 acta-faac. 

3. Tha aap on paga 67 naada to hava cba Saa Pallpa Projacc aarvlca 
•raa labalad. (Saa ancloaad aap) 

4. Ob paga 91. tha sacond paragraph on tha right baginBing with 

tha aacond aantanca; It ahould raad 'Proa tha raaaivoir. tha 
Pachaco Tunnal «ill convay watat to a eariaa of cond«ll» and 
•wancuallr to both countlaa. Existing facllltlaa la tha Santa 
Clara araa and tha San Juato Raaatvolr will atota and control 
tha watar." 

3. Oa paga T of tha agraaaant, San Juato laaarvolr ahould ba llacad 
with tha facllltlaa of tha Unicad Stataa. 



[ _^^„,r..^ i AND ITS SERVICE AREAS 




Figure 15: THE CVP 
ITS SERVICE ARI 

(Service Areas Shaded) 



uJ^Ul^u^ (L. ^i^^^ 



Encloauraa 




^■f It lOuMlW 




co:: -».- — 

tMlUl ■ 

Ull ■ 




„ /?P^7<P^r 


3l 

SACRAMENTO VALLEY 
WESTSIDE CANAL ASSOCIATION 


d^y^'ti:/^ 


ROUTE 1. BOX 1070M 
WOOOLANO. CALIFORNIA 9S096 




January 33, 1986 




Mr. Bob Schroadar 

Cnvironmantal Baaourcaa Oapt. 
Buraau of RaclaAation 
3800 Cottaqa way 





SacraaancA. CA 95835 

REi EIS/EIR on COA 

D««c Hr. Schroadaci 

Tha following ccnaanta ara aada on bahalf of tAa Sacraaanto Vallay 
Haatalda Canal Aaaoclation. Our chlaf concatrta in xm%*tA to Cha CIS/CZlt 
ara aa foll9<ai 

1. Tha US. ahould adhara atrlctly Co tha provlalona of tha California 
Watacahad Protactlon Stacutaa (WTS) ISaa attachaanc haiaco) . Tha CIS In- 
dlcataa a dlaraqard toe tha fPS. 

3. TTta propotad proqraa for contracting with tha Stata of California 
for tha aala of Intaria watar to tha SWP uaaa data for tha watar raqulrananta 
of northarn California which ^m far balow thair ultlsata raqulraaMnta. 

3. Wa ara concamad that tha EIS accurataly praaant tha facta, which 
It doaa not alwaya do. 

California Watarahad Protactlon Statutaa 

Undar " "y* you atata that *tha pro]acta ara not to ba oparatad 

to aaat pradatarminad ylalda, but rathar to flrat »m»\ tha naada In tha 
araaa of otlqin, Including tha dalta watar quality itardarda . . . *. That 
la a good atataaanc and la in accordanca with pravaillng law and court 
daclalon. Dnfortunataly , tha propoaad COA doaa not adhara to tha law in 
that raapact. Paragraph ia(h)(3)(ll) atataa that *tha U.S. will la^oaa 
daflclanclaa on watar purchaaad by tha atata In a aannar conalatant wltJi 
CxhiUlt K.' C«hU)lt -R* providaa UAdar paragraph lib) aa tollowai 

'In any yaar that tha Contracting Offlcar datarwinaa thara la a ahortaga 
In tha quantity of watar availabla to cuato^ra of tha Unltad gtataa 
(coa tha CVP. tha Contracting Offlcar will apportion availabla watar 
asonq tha watar uaara capabla of racalvlng watar froa tha aaaa CVP 
Cacilitiaa by raduclng daUvariaa to all auch watar uaart by tha %m.am 
parcantaga . unlaaa ha ia prohibitad by aaiating conttacta. CVP authorlga- 
tlona or h« datarai^aa that aoaa othar aathod of apportion*ant ia raquirad 
to pravant undua hardahip. In tha avant raducad dalivarlaa ara nacaaaary. 
tha watar iuppllaa for both aunlcipal arwl Induatrlal uaa. and agricultu- 
ral uaa ahall ba raducad by tha aa^ parcantaga for aach contractor." 



^_ -fOtJlWli«f 

'_,^LSOti SOoTh C*>«»<. 

l^^ lMraiMaN-Sta*Jaaa«* 0«><* 



^ %AH JOAQUiH fllveR 

^-mOEIti C4N4L N^ 
SAJI LUIS CANAL 



UM IWS Hi '^T^ '/^Hl 

K / K 



\ 



DELTA- tlCNOOTA CtHH' 




31 



January 33. 1986 
Paga 3 



All watar uaara of tha CW, including tha swp undar tha propoaad contract 
for intari* watar, will ba cut back during a drought by tha aana parcantaga 
ragardlaaa of whathar or not any auch uaar or uaara ara in a watarahad of 
origin. A pariod of droognt la not only a vary critical tuna for uaara, 
but is tha praciaa tiaa wnan uaara in an araa of origin would naad aoat 
to raly oa thair priorlcr of uaa undar Sactiona 11460-3 CallCornia Watar 
Coda. If this provision of tha COA baconaa law. it will constltuta a daclar- 
ation of intant on tha part of Congraas which will tAk'a pracadanca ovar 
California watar law. Uould it aaraly aodlfy tha California statutaa, or 
coaplataly nullify thaa> In any avant it would raault in litigation. 

Paragraph 1(b) of fahiblt *E' should Inataad spaciflcally provida that 

a claar dlatinction ba drawn batwaan watarahad uaara and non-watarahad usars 

as two saparata claasas of uaarat and praaarva tha priority in uaa for thosa 
in a watarat^ad. 

Tha proposal to coatrsce for Intarla watar for tha SWP la • propar 
arranganant aa long aa thara is a right to racall tha watar whan naadcd 
in a watarahad of origin. Paragraph 10(h1<3)(i), provvdas for thia. Thara 
ara, hovavar, inaufflcla^t aafaguards for tha racall withia a raaaonabla 
pariod of tlAS. Sactiona 11460-3 of California Watar Coda ara far ^ra 
ftra about auch protact^sn than la tha propoaad COA. Thara should ba languaga 
prohihlting tha construction of aatanaiva facilltiaa for tha uaa of auch 
watar aa thosa facilltiaa auat avantually ba paid for, and that can only 
ba dona by aalaa of watar. Whan tha watar is withdrawn tha IncosM stops. 
Thay than hava ao«athing Ilka aquattar's rightsl Thara should ba claar 
guldallnaa for thia rathar than tha vagua and briaf lanquaga davotad to 
It. If tha propoaad COA la anactad, it will ba tha antaring wadga and tha 
firat bit of fadaral lagialation (daclaration of fadaral intant) to Mjdify 
tha county of origin and watarahad protaction statutaa of tha Stata of Calif- 
ornia. 

Tha County Suparvlaora Association of California (CSAC) ccaplatad a 
atatawida watar policy study. Thia writtan raport waa approvad unanioously 
on Movaabar 14. 1985 by tJ\a CSAC Canarai Asiaahly. All araaa of tha Stata 
vara raprasantad on tha CSAC Taak Porca which praparad tha raport. A spaciflc 
saction daala with araas of origin, watarshad protaction. and alao aaAaa 
atrong racaiMindatlons la ragard to fadaral pro^act authorising lagialation. 
A copy of that aaction of tha raport la attachad harato. TTiis is avan aora 
important whan wa conaidar tha nast point. 

Watar Osa Sata for tha Tahaaia-Coluaa Canal 

Tha Tactutlcal Paport of March, 1984 on 'Datanination of Annual Uatar 
SuppUaa for CV» and SW»*. is alaply Inaccurata in ragard to tha Tahaaa- 
Coluaa canal In ganaral. In Tabla 3 (paga ^ of tha Raport) tha Sacrananto 
Canala Unit of tha CVP provldaa for dallvary by 3030 of only 430,300 acra- 
faat annually and Indlcataa a 19ft0 d^nd of only 135,000 acra-faat. 



122 



31 



J«nuAry 22, 1986 



Tha 8ux««u of Racl*a*cion pt*p*tmd « wrlctan raport on OMlr w«c*r 
■Arkaclnq pioqraa for cha Tahuu-Colua« c«n«l on Octob«r 37, 1977, a copy 
of whlctt La atcachad haraco. Through Raach • (and of ttim canal) tha Buraau 
of Raclamaclon contractad to sail 313,700 acra-faac annually, and lacoqnlKvd 
a pocantial additional daaand of 361,900 acra-faac, or a cotal of S74,6S0 
■cra-faat. In addition, Ic aatimatad an additional 40,000 acca-CaaC foe 
th« Yolo Z&nora Hatac Dlatrlct which la nov a part of tha aarvlea araa. 
Th« currant aarvlea araa would than hava a daaand of 614,650 acra-faat annually. 
Tha propoaad waataida canal would call (or an additional 108,000 acra-faat 
annually, brinqlnq tha total Tahaaa-Coluaa canal daaand to 733,630 acra- 
faat. Tbia La In aharp contraat to tha Tachnical Raport flqura of 430,3001 
Xa fact, tha lattar racOfnlzaa only 99% of tha potantial daaand. Tha TachiUcal 
Maport Inaattlnq forth a 1960 daaand of only 13S,0OO acra-faat. waa aia- 
laadlnq whan, in fact, aa lonq 490 aa 1977 thara waa 313,700 acra-faat undar 
contract. If wa addad tha additional watar ra^uastad and aaadad by axiatiaq 
diatxLcta, tha total daaand would alxaady ba in aacaaa oC 430,300 acr*- 
faat. 

Thia Is part of aa onqoinij procaaa of naqotlatlnq tha sala of intaria 
watar to tha SWP. Thi* aala will ba at tha hiqhaat poaalbla prica aa scat 
of thaaa usars in tha SWP will ba aunicipal and Induatrlal uaara. Our watar 
raqui.rcaanta ara apparently baing aOjUjaizad In thaaa rapoets and naqotiatlona 
in ordar to aall aa such watar aa poasLbla alaawhara at a hiqhar prica. 

In concluaLon. wa faal that a atrongar and flraar racoqnitLon of tha 
California watarahad protacclon lawa ahould ba incorporatad into ti\* COA 
ao aa to protact all watarahada. Ttaaaa watariKada alao Includa tha dalta. 
Xa it La, tha proposad COX subvarta thoaa statutaa. Wa alao ballava that 
tha Tahama-Coluaa canal aarvica araa should ba axpandad to full capacity, 
including tha ranainLog land in Yolo County and Solano County, and that 
thair full naada not only ba racognirad, but racognitad aa a firit priority 
in uaa for tha CVF. If thaaa things ara not dona, tha propoaad COA would 
ultlaataly allAinata tha priority In usa of watarahada of origin, including 
that of tha dalta. 

Wa would appraciata haaring froa you ragarding thaaa coocama. 

Thank you for your conaldaration. 



Sincaraly yours, 

Twyla J. Thcnpson 
Prasidaae 



<l£^ 



-J 



TJT/lf 

anclosuraa 

cci Hon. vie Fazio. H.C. 

Hon. Caorga Millar, H.C. 

Hon. Cugcna Chappia, H.C. 

Tehama -Colusa Watar Usaei Aaan. 

Central Valley Project Water Assn. 

David Houston. Regional Director U.S-B.R. 



31 



California W*f r»bed Prot«etlon atatutf 

111460. D«pclTal o< pclot clgbt to vatar to lupply 
vatocabad araa 

In tbo conatcuctlon and opccatlon by tbo dapaitsant of 
any ptojact undar tba provlalona of tbla part a watarabad 
or araa vfoaroln watoc oriqlnataa. or an acaa Iraadlataly 
adjacant tbarato wblcb can convanlantly ba auppllad witb 
watar tbarefros* aball oot b« dcptlTcd by the dcpartaant 
dlractly OC indiractly of tba prior rlqbt to ail of tba 
vatar raaaonably raquirad to adeqoataly aopply tba 
banaflclal naada of tha watarahad, acaa, oc any of tba 
Inbabltanta or propacty ownaca tharaln.* 

*Statutaa of 1980. Cb. 632 attaaptad to anand tbla aaction 
but tba aaandmant vaa rajactad by tba votara on a 
rafarandua vota. 

S11463 . Czchanga of watar batwaan watacahada or aceaa 

In tha conatcuctlon and operation by tbt depactecnt of 
any project under tha proviaiona of thia pact, no eichanga 
of tha water of any watecahed or area for the water of any 
other watershed or area may be nade by tha depactoient 
unleai the watar cequicements of the watershed oc area in 
which the cichange ia nade are first and at all times mat 
and satisfied to the extent that tha requireacnts would 
have bean sat were the eichange not aade, and no right to 
tba use of watar shall be gained oc loat by ceason of any 
•ucb axcbanga. 

5 11128 . Llmitatlonat Application 

The llnitatlons prescribed in Section 11460 and 11463 
shall also apply to any agency of the State oc Federal 
Government which ahall undertake tha construction or 
operation of the project, or any unit thereof, including. 
bcaidea tboao apecifically deacribed, additional unite 
which are conaiatent with and which may be constructed, 
■alntained, and operated aa a part of the project and In 
fuctbecance of tba alnglo object contemplated by thia pact. 



ijl 



31 



XV. AAIA5 or ORIGIN 



I aatiafactlon of watar naada ahould ba asaurad for all 

*?*■■ ot origin. State law ahould provide that only 
^/iurplua water May be axportad froa aroaa of point of 
origin. Thia principle auat ba applied to all 
beneficial uaes, including inatraaa naada, and auat 
apply to all water aupply aourcae, including 
groundwater. Counties support thia protection so that 
all reasonable and beneficial needs are aec. Theaa 
protections should provide that only those waters 
surplus to tha reasonable ultimate needs of the area of 
origin should be Bade available for beneficial uses in 
other areas. In addition, the cost of water 
development to users in areas of origin should not ba 
Increased by effecting a water export plan. In all 
state and federal project authorizing legislation, 
county of origin protections should be reaffimed ard 
the reiated feasibility studies should clearly identify 
and quantify all reasonable future needs of the 
counties of origin to permit the inclusion of apacific 
guarantees in the authorizing legislation. 

Counties of origin should be afforded financial 
assistance in developing new high coat water facilities 
to provide an equitable distribution of watar costs to 
all usara. Host of tha lower cost facilltiaa have been 
developed and are benefiting downstream users. 



"k'/t.,,. 


ta«a 


f>^-i^^/ 1/^//,^ /';-.7„y 


.-«.. 


:-aas« 


aa Ts 






B«fa»fl 


^•C^^^ 





h^t'. 



2 2, foe 9,Soo J2^ano 

t if. <nr< - lij Tim 

T•^*f 3/2, 7oo -|- 2 c./. 9ffl ^ 7*7^/ C Cn 



A'<~4./ yn,/ 'V-'y * '•».-' 









..;. 2. 


?.'.->-i 




'•■7? 


I.i .. 


2 J on 




i-lf 


l./i 


•f.'Oa 




ill 


>:■! 


nno 


/. 


•ni. 



i^-%i -Uc /%-- / 



'0 n:>r» ftr 



/O/, (/jy li-" 



7 r - /.'. 



IJ /lit >*->** /^»^ ff**^*mf/ *•* lotly a^ P2'.; ■':, x,r. '-■*■*• , /I J'.- Art 



123 



! 



miTiD natM nrunaar or ni onuioi 
■DU«o or uoAauion 



niLic uum ui 



aoiwnrrt am ni UAn tw/aommrtu. 
iiriiCT •Tknmrr ud uro*T (uif/iui 

roi m ntopoMD cooisnATiD omtATioii 
MMMMmm (COA) ■nwm m o.i. iUUAD 

or UCLAMTIOI'I CBmAL VALXIT rftOJICT 

un> ni CALirouit tTAn orumBiiT or 

■UU lUODICI'a RATI aATII rtojicT. 



(AOuuBno na, odmido toon 
uouLmno, ULirotiiA 



mUUT, OCTOM* ]>, If IS 

Tiio r.K. 



■•pectad by I 



■bttrry L. Lloy 
C» 10. 9007 



C A P I T O I. nCPOnTER* 



3 
9 
4 
9 
< 
7 
I 
* 
10 
11 
1] 
1] 
14 
19 
It 
17 
li 
1> 
10 
II 
12 
11 
14 
19 



■miM rmei. 



rot th« OapbctBsnt 
at DAtai kaaouoii 



ror tb« D«p«rlm«ne 

of tb« XBt«tlOII 



J«B«| 0. NcDanieJ 
L«»ranc« A. Hullnli 
Oailaa A. 6bo«BAAcc 



bob bcbtoadei 
Jtm»m I. Tuinai 
r. rbllllp aharp* 



Cftrmx. nroitus Itio 44(-i797 



1 
1 

1 

4 
9 

< 

7 
i 
t 
10 
11 
11 
11 
14 
19 
14 
17 
li 
II 
10 
11 
11 
1] 
14 
19 



1 MB H 



iMOtaacxuma 

Jaaaa 0. bcDanial 
PhUllp narpa 
Cbaclaa b« 



alcbai« (potta 
oarald Scb^obar 
■ocvaA bturv 



T 
» 
17 



1 
1 
I 

4 

9 

( 

7 

i 

• 

10 

11 

11 

11 

14 

19 

It 

n 
It 

19 

10 
11 
11 
11 



a^...— n r.iT.n^t. »i.ai.. nr^^r. 1, 1 aa< 7.10 a. a 
— oOo-- 

m. BC MBia.1 Kail, It la 7iI0, aad tbat'a tba tlac 
«a abbogBoad tba aotloa to bafllanlat tba baatloq. 

rlcat, I'd Ilka to latrodaoa tba paopla at tha baad 
tbbla. I'b Jib aaOaBlal, Cblat of tba Canttal Olatclct, tba 
Oapaxtaaat of Matac ■aooasoaa. Oo ^ dgbt, bob acbroadar, 
■uabo at aaclaBattObi Jla Tubat, tcoa tba bailoBal 
■oltoltoi'a OCttoai tbU ttacpo, baslooal rlaaalng Qttloac 
far tba boxaao of bbclamatloa. On ay laft, cbuck Sboaaaaci, 
aa attotaay vltb oar la«al ataff, Dapartaant of Hatct 
baaoocoaai aad Laciy Kalloii. «bo la Cblaf of tba Dlvlalor. 
of Opacatiooa. 

Lat'a aaa. Do wa bava aqr capcaaabtativaa of alactad 
attldbla la tba aadlaooal 

1 bl«bt aabOUBoa, tba ■•atlB9 vUl ba cacocdad. lb* 
procaadlbga will ba a^Barlaad. Ooplaa vlll ba avallablt If 
a^foba ae daalcaa. 

■ow, tba baadoot tbat you laoalaad wbon you acrlvcd 
did probably a battar job of ouUiolB9 tba purpoaa of tbls 
■aatlog tbaa I oaa. nia baalc puipoaa la to 9«t public 
oplBloa OB tba docnsaBt tbat aaa prapacod to indlcata th« 
aavlro^oBtal ooBaaqoaaoaa ef altlag and laplaBantlB9 tbc 
OooEdlaatad Oparatlaf bfraaaant. 

Iba paooaaa tbat va tollowad aa tbla. bagibbloq In 



cbriroL monub OKI 440-1797 



CAT IfO. ttlOCTUJ 



(91(1 444-1797 



124 



1 


2 
*ii9uat of lti3, «• bald * aarUa K pablio aoopla« aaatlaia 


- 


1 


3 i 

1 
ladloata if yoo plaaaad te aaka a atataMnt. And ao (ai, I | 


2 


tkrasfhoot tka aut* to fatkai pabllc laput aa4 taciim 




2 


daa't tbiak oa bara — ak, m got ona. I intandad to aay 


J 


actaallT what iboDltf ba oooaldatad la pcapatlaf tba 




1 


va'd call oa too la tka aidai of your arrival and your i 


4 






4 


iadloatloa tbat yao aoold llko to apaab. But «a hna on« 


S 


rallavlat tbat, la 1II4 aad ■•>, tkara Mia aiaaioui 




9 


apaakoc, ao that' a falily aaay. 


< 


puUlc aagotlatlng aaaalona oa tba atraaaaat. afcaaaant vaa 




< 


■a oould oak — Mil, I don't aoao bara to aay tbat. 


7 


laacbad oa tba eoatiact, dialt oantiaot, bay 20tb, ItOS. 




7 


I .aa going to aat yoo to try to llalt it to about tar, 


• 






• 


■Inotaa. But If you do tbat, m «U1 ba out boforo tb« 


> 


■tataMat/tOTliaiaantal tapaot bapoit la laptaabac o< tbia 




• 


ballgMa'a ooar. 


10 


raai. Ma'va allovail (0 days pobllo laataii, a (O-day public 


1 


10 


If you baoa orlttaa atataaanta you'd lika to aubalt. 


11 


carlao parlod, and tbat parlod alll ba op uowmbmt lltb. (a 


i 


11 


you can aabalt tbM aad «a olll Induda chaa in tha raccrd. 


12 


oa oUl accapt atatsaata oc ni— aiila oBtll tbat data. 




12 


■toff la aoallabla to ana»ar guaationa if you have 


11 


Aa I ladlcatad, «a olll ba boldiag a aaooad aaaUof 


1. 


13 


gaaaUoaa dorlag tha «_oat porlod. Booaoar, I oould aay \ 


14 


U Concord oa tba 7th of wxaabai at tba coatca Oeata natai 


1 


14 


tbat If tha gaaaUoaa lagaira a aora ia-daptb aoaluation 


IJ 


boaney otflooa. 7i30 p.a. 


1 


IS 


tkaa M oaa tendla bora, *a oUl loapond to you in ■ritln9 


1( 


rollooiag that faatlag and (allaalag tba pabllc 


u 


Id 


(alloalag tho MOtlng. 


17 


rarlao parlod, oa oUl ba laootpocatlaf Uto tba Maal 


1 


17 


I'd lUo to atatt tba MaUag by aakiag Br. »bil 


11 


lU/tn tba aainta tbat «o laoaioa. *ad (olleola* tbat. 


1 


11 


Macpa to aaka m^inl ■ aoM ocaMata toi tbo Baiaao of j 


1» 


tba botloa of Botocainatlaa aUl ba (Had It tba 


L 


1* 


kOllMtlOB. >hUT 1 


20 


oapaitMaat — botloa of DotaialaaUoa oUl ba (Uad by tba 




20 


IB. aAini tbo Boraao of BoclaMtlon, the 


21 


Dapactaaat <oi tba Ilil and a laeocd of Daelaloa vUl ba tii* 


I 


11 


Baiutaant of latoiloi aad tba Ateiaiatratlon aopporta ao»« 


22 


oltb tba loioaii to tha lu. 




>> 


lagialatlon oa tba COA. Ba aia optiaiatic tbat oa .Ul got 


21 


■a Mold bopo that tba pcooaaa ooold ba ocaplotad by 




U 


a bUl la tba aMC (ataia. Ooagraaaan Billar'a Bill 3113 


24 


aboat Jaaoary o( aaat yaai. 




24 


baa paaaad tba Booao. no Baaata la no* acbodollag a j 


2S 


■baa yoD aicload and algaad la. yoo Mia aakad to 


■ '' 


29 


MOtlng on tbat bUl. 






C^nCL uiomu — (tit) 44«-2757 




CAtnCL BIfOBtBBS — OK) 44<-2797 


1 


4 
Ma bara baao ooitlag aa joint paitaaia, tba laiaao o( 


- 


1 


- - - ■ 1 

9 1 

! 
i 
Lola laMrrall. Aad »kat Ma an aapiacadantad (aatuia that 


2 


badaaatlon and tba dtata, toi aoaatlM oa aagotlatlag tbla 




2 


giav oat at tbat, tka Jaiat ooaairiilp of that facility. 


3 


agiavMnt and In doraloplng thla aavlloiMaotal doooaant. 




) 


■bleb inoladaa tka Baa Lola Baaarroir and a atratch of th< i 


4 


Aa Jla aantlonad. oa aia looking to got ao«o iiiiaaiita 


,^ 


4 


CallfocBla Bqaadaot tkat la aaad to carry both rodaral and 1 


i 


on tba anilioiBantal dooiaaat ItaalC, altboat aaoaaaailly 




i 


BaiMB Mtat aad oat of «blch m aarra radaral ooatcMci, 1 


< 


looking foi eoBMnta on tha atelnlatiaUn bllla oi tba 




< 


aad tba Dapaiaaat of Batar Baaoaioaa oporataa tbat atratch. j 


7 


oongtaaalooal bllla oc on tha G0& Itaalf. Bat «a aio 


[^ 


7 


BOO, tbat IMO agiaoMnt callad for a aora apaciflc 1 


i 


oailoaaly looking for your oaaaanta on tha anvliooBaatal 




• 


oporatlag agraaaaat. Back la IMO, oa bad yot to (inlah < 


• 


dociBont. And wa Intaod to tiy and ba aa caaponalva to 




• 


oaaatcooUoa o< a giMt Mqr of tboaa facUitlai. | 


10 


tboaa ooaaaota aa poaalble. 




10 


■ogoUatloaa ataitad la Mily '(l, ooaUauod through '71. oi 


11 


ML ac DAain.1 boo Cboct Iboaaakai «U1 aaka a bilat 




11 


into *71. noro oaa aaeckoi agraaaant than. Tbat agroia«nt 


12 


otataaant foe tba Dapaitaaat of Matac baaoaioaa. 




12 


vaa not tiaallaad. bat it did fora tbt baala for annual 


13 


■L aociKUlli I think it Bight ba balpfol to glTO 




13 




14 


paopla a littla bit of blatoiy and to point oat tba pcooaaa 




14 


pco)octi. 


19 


tbat oaa atUiiod la aiilTlag at tba Diaft Oooidlaatad 




19 


«o than laauaid aagotlatloaa la tha lata aarantlci 


1< 


opaiaUag Agiaasoat Itaalf. 


'_ 


1* 


aad baoa ariiood at tha pcaaaot draft. 


17 


Ihia agiaiMnt baa ita gaaaaia In an agiaaMat that 




17 


I Ulnk it' a ladicatioa of tba fact that •• don't 


11 


waa atacotod on Ray Ktb, IMO. Ibat agiaaaoot «aa ffory 




10 


baoa a tao tkeaaand paoplo bora ooadaring ohat'a going on, ^ 


If 


iapoctant boeauaa it laaolTad at tbat tlaa dlipataa tbat tba 




10 


1 
tba pcoooaa tbat vaa oaad ia tka laat four or al> yaara on 


20 


(tata and rodaial eovamont bad o>ai tba aatai bigbta 




20 


tbo agraaMBti aad tbat Ma all of tha aagoUatiag aaaalona i 


21 


Application that bad baan (Had for both pcojocta, aad it 




21 


1 
wore BOtlood and opon to tbo public. And aaiv of tb* 


22 


vaa a gaaaial vay to baadla a abaiiog of iboitagoa, aa it 




22 


aaaalona «a bad bad aoro poopla in attandanca watching ua 


23 


«ai«. 




13 


alt aoioaa tba tabla. tba Baiaao and tba Dapartaaot paopla, 1 


24 


Bat tbat agiaaBaot, it alao doaiad tba way foe 




24 


aa M vant poiat by poiat tkiougb aiiloing at tbla 




2S 


appioral of tba Ban Laia Act (oi tba ooaatiaotlon of tha Ian 


' 


29 


agiaaaont. 






CATinL mOKnU ~ (tl(l 44t-2757 




CAfinL BXfOmU — OlO 444-2757 



125 



1 



1 
1 
> 

4 

5 

t 

7 

I 

> 
10 
11 
13 
11 
1< 
1» 
1( 

n 
II 

II 

30 
21 
23 
23 
24 
23 



1 
2 
3 
4 

3 
I 

1 
I 
I 

10 
11 
12 
13 
14 
13 
U 
17 
II 
If 
20 
21 
33 
23 
34 
33 



lou Bay h»« BOtlo*4 tkat la tka IIK/(Ii, It'a — at 
laaat I can apriaclata tha fact. It oaa aitdciUt toe tbt 
Matt tkat kad ta *(*vu« tkla t« aaal «ttk. (Maaaa It* a 
oa aa a«ca«aDt and aot oa aoM Uad of taaflUa fcojact 
t*at yoo caa bara altaiMtlraa to, that r<x> o* laadlly 
Idaatlty. 

It* a takaa oa roovhiy 23 yaaia to cobo to aa 
atiaasaat. ud It vaaa't la tka oarda toi tka MfoUatota 
to aofotlato 0<K llaallr tkcao oi loai oltoraatKo 
aftonoata to M aolaetod, qalto fcaakly. If a ]aat tlsa 
aatuta e< maf agioaaoot vbaca yoo aca taklnQ poaltiooa and 
c^pxoBlalng and Daccovlog dowa to vbaco yoo tlaally bara 
laaolTod all od you laauaa. 

naia la a aajoc point InolTod la thla Cooidlnatod 
OpacatlBfi AgiaaBODt that 1 vaot to vlod op on. Aad tbat ia. 
It la daalgnad ao tbat botb pco]acta aca opotatad to Mat 
vatai qsallty coDdltioaa la tho Oalta, caitala atha^cda, 
aad alao tfeo la-baala aaada in tka uaaa ipaUaM at tba 
Dalta and la tka lacrasanto Tallay. 

ABd tka projacta ara opatatod to aaat tkoaa tlrat. 
It'a aot opaiatod to Mot aoaa pcadataraiMd ylald o< tko 
pcojaet. va Mat tkoaa Mada la tka aiaa o< odfla aad tka 
Oalta vatac quality ataadafd. iaoladlag tka flew 
laqolKMBta, oartaln ootflo> taqalCMaata tkat aza 
Moaaaacy. Iboaa aca all ooatalMd la liklkit A at tka 



CktmL UlOmU — (tit) 44*-3757 



tka kaciaaaato and Caatial vallaya. tka aaaaaaat Mtlaad 
araaa. aad to aaauco tko pacpotuatloa ot otkac watlaad and 
clpaclaa babltata tkcoogkoot tka Oaatcal Tallay ot 
CaiUocola. 

la. I ballovo It vao, 1134, tkaca vaa atcoag lagal 
autkoclty tkat tko CVf autkocUlag loglalatloa vaa aaaodad 
to aspcoaaly agtbodaa tlift a«d olldllto pcotactloa aa 
pocpoaaa of tko Oantcal Valloy Projoct. Va oadacataad tkat 
tkaco la a 1134 lollcitoc'a oplaloo by tko iDtadoc 
Dapoctsont, vblcb la atill oitaat, tkat oadacaoocaa that 
ooaBltaoDt. 

And tboco baa alao baan aa ovolBtloa la lodocal and 
ftato vlldliCa lav, and va acgaa tkat tkaca la a voCT tick 
Bltlgatloo coapoaalblllty, laoDg otkac tklnga, mdac tko 
■Btloaal lEvleoMantal Policy Act, tko UdaBgacad (padoa 
Act, tka riakaad Vlldllta Coocdinatloa Act at tka radacal 
laval, aad at laaat oodoc Calltocala'a late&pacad fpaclaa 
Lava aad tko Matac Coaat Davla-Dolvlg Act appllcablo to tko 
Dopactaaat of vatac kaaoucoaa. 

Claacly, botk tko Caotcal ?alloy Pcojoct and tba 
•tata Matac Piojact bara ooatdbotad to tko loaa of 
aaCiitiaT I il votland aad dpoclan habltata tkcoogkoot tba 
■aoiaBaato aad Oaatcal Tallaya ot Callfocala. ttoca baa not 
bMB aa adaqoaU caaolotloa to pcoalda toe tka Bltlgatloa of 
tkoaa paat loaaaa, aoc to caaolva altlgatloa toe loaaaa 



CAPnSL IDOinUI£ ~ 111(1 44(-2737 



1 

2 

3 

4 

3 

« 

7 

I 

• 

10 

11 

12 

13 

14 

IS 

It 

17 

II 

II 

2* 

21 

12 

33 

24 

2S 



1 
2 
1 
4 
3 
t 
7 
I 
I 
10 

11 
11 

13 
14 
IS 
II 
17 
II 
II 
20 
21 
12 
23 
24 
23 



Coocdlaatad Opacatloa kgcaaaant. 

Only tkaa aca tka pcojacta abla to oapoct vatac fcca 
1^ 0«lta. kad tka agcaoBaat, by ita tocaa, la aot tataadad 
to atfact tka clgkta ot aay tklcd pacdoa. It* a an 
agcoaaaat batvMa tka Dapactaant ot aatac kaaoocoaa of tka 
ptata ot Callfocala aad tka aDcaaa ot kaclaaatlon. 

Vltk tkat, I goaaa, by vay of bactgcooad, tkat* a all 
I veald kava to aay. 

m. BC OMiIB.1 ttaala, Ckact. 

S faaaa vltk tkat point, aov 1 vould aat foe 
oCBMaota. «ba oaa aaaa tkat I bara la Ac. Uchacd Spotta. 

Ni. Ppotta, voold you ploaaa Idaotlfy youcaolf and 
vboa yOB copcaaaat toe tka capoctoc, ploaaa? 

a. nOTTti laa. I'a Uckacd apotta, P-P-O-T-T-t, 
Calltoxeaa kapcoaaotlva toe tka Dafaadaca of Mildllfa. 

Aad by vay ot kackgrouad, Dafaadaca of Mildllfa la a 
Mdoaal Mapcotit aaahacahlp oegaalaatloa koadqoactacad In 
■aAlagtoa D.C. X rapsoaaat appcoalaataly 12,000 ot obc 
Calitozala aaahaca. 

■kUa Dataadaia at «ildl Ua awpocta tka COA pcopoaal 
fOMcally, aa tax aa it goaa, va tool tkat It doaa not go 
aaacly tac aaaogb. 

tka ODA paavoaal la tlaaad baoaoaa It doaa not 
pcovida toe tka taaolodoa ot flodlag aocora caliabla vatai 
aaazoaa toe Padaeal aad Ptata vlldllfo cafogaa tkcoagkout 



CkPnCL mtmrtMM — IIIO 4M-2737 



vkick B^r eooac la tka tstaxo. 

la tact, tkata la a aav Mciakla tkat kaa adaaa in 
tka laat ooapla of yaata. Aad tkat la tkat, glna tka C»P 
aad Ptata Matac Pcojaot at leclgaUoa la oactaia laoda ot 
tka aaataca daa Joaqala Tallay, va aov kava a aalaalia 
pcablM. Aad aacllac tkla yaac, botk tka latacloc 
Dapaxtaaat aad ttata at Callfocala aaaooBoad tkat vlldlif* 
acaaa voold ao laapae eaoalva ae«a ooataalaatod vatai 
aappllaa. tkoa tac, tkla kaa aapadally attactad tka Ban 
Lala katloaal VUdllta katoga, tka laatacaoo aatlonaJ 
VUdllfa kafaga, aad va aadaeataad tkat aoaa tlova aay bo 
dlalal^ad ia tka acaaalaada Matac Dlatdot, vhlck kaa a 
m^^mt ot Padaeal aaaaaoata foe vatacfovl poxpeaoa. 

Ikaca la ooacaca tkat. la affoct, tka CTP and tba 
•tata Matac Ptojoot kava aa obllgatloo to pcovida faatttr 
<aallty aatat ta oftaat tko loaa of vatac tkat vaa otkacvlae 
atallakla ta tkaaa vUdlita acaaa. 

Ma tlcmly ballava tkat tka COA Mould bo bcoateaad to 
eaqoica aatlMaetocy taaolodon of tkaaa flM and oUdllfa 
iaaaaa peine to aay factkac oootcaotiag of vatac foe 
agcieultBCa, aaalolpal oe ladaatclal aaaa. ladaad, vt 
ballava it voald ba pataaUy Ulagal tot tka (ocmo oc tka 
Itata to attaapt to preooad to kava factkac ooatcact of 
caBaiaiag aaxploa aatu tkaaa Iaaaaa aca caaolvod. 

Ma ballava tkat tka Dcatt ■arlcoMaatal lapact 



CAPI1CL inomk* — (llil 441-2797 



12 6 

















10 


- 


11 i 




1 






1 


teaorlba vbat voold acour vltb tba abaanoa ot tboaa 




2 


advjuauly coDildai «ltb«i, foi lack o< » Mtui can, (bat 




i 


baaaflta. tta (aUara to laploMnt cvr and ttata llatar 




3 


M Kould oonatraa aa aa -optlaiia tlik aa4 vlldllta 




) 


ttojact tl* and vUdlita purpoaaa and altigatlon 




4 


altacsatlia* or a 'vocat caaa aoaaarto altaraatlva. ■ 




4 


abligationa and ptoaldlag laadaquata vatar for rafugaa. 




5 


I'll aaaedba tha opUsK aaaaarlo. 1( I uy. 




9 


vaUaad ttpatiaa habtuta, aad to tacoaeUa tba pcaaiblc 




( 


Jtctually, I'd lika to jaat pcoaUa aoaa back«ioai4 on tha 




( 


aapaaaion of agrlcoltaral landa through tba contracting of 




7 


■atlonal InrlceoMaatal rollcy Act la paxtlculac that* a 




7 


laaialag ylalda In thoaa pcojacta and through arrangaaants 




• 


applicabla to tka racial luaaa of ■adaaatloa. bid <a 




• 


that Bay ba aiacutad. , 


• 


kara tba Calllocala BaalroBaatal Ooallty kct aa aa aaalof 




t 


rlaally, to vhat dagraa «o«a aalatlng and praapaetlva | 


10 


BBdac Btata lav. 




10 


vatar ooatracUag aaaoarbata tba pcoblasa vltb aalanlia and 


11 




1 


11 


aalt prohlaBa la drain vatar la tba Cantral Valley? And 


1} 


to bava a full daactiptloa of aay pcojacta that aay 


1 


12 


again, va ballava that, in aaaanoa. tba draft docwant that 


11 


algoKlcaatly alfact tha aarlcoaaat, and alao that a 




19 


va'ra looking at tonight doaa not gi»a an ada<ioat. 


14 




1 


14 


daactlpUon o< althar at thoaa altarnatlvaa, and va f«l 


15 


public tha opportunity to aaa dlffaKaat choioaa. 


1 


19 


that dOh aad a aaihat at othar lava taguira that candid 


16 


■a (lad that thia Dtaft ImlcoiBantal IBpaet 


1 


If 


appraiaal. 


n 


Ctataaaat and lapoct doaa not (acllltata thoaa pocpoaaa. 


1 


17 


■a aadaracand that lagialatiea vaa tacaatly 


11 


agaia, thcough tba abaanoa at altbai aoct ot a baat caaa ei. 


1 


It 


Istxadaoad in Oangraaa ta aathorlaa tba Hid-Vallay Canal in 


i> 


ceavacaaly, a worat oaaa altatnativa. 


_ 


1> 


tha oaatial vallay. It' a taaciaatlog that va ara aort of • 


20 


*a optlaal altainatUa >anld aat foitb tha aaada at 




10 


laag «ay into thla OOh aatharUiag laglalatioo pcocaaa, and 


21 


stata and fadacal caXo^aa foi callabia vatar aoatcaa* 




U 


la ooagraaa aev va hava a bill U tba hoppar to authoriic 


22 






12 


yat aaethat aatat tcaatfar (acUlty la tha Canttal vallay i 




23 


lactaaanto and Tdnlty klTaia, and atharalaa aaat a nvbai 




IJ 


aad yat va havaa't caaolvad aaqr ot tha (oadaaantal 




24 


at tba concaraa that I ouUlaad a BOMat ago. ~ 




14 


«aatlana aboat tl* and vUdlita pcotactioa via-a-ria tbcsr 




29 


Cb tha othai hand, tha mat oaaa aoaaule ikoold 


, 


19 


aatar pcojaota. laaaad, va doa't aaan aaaa to raoognlia tba 






OTTta. UKSnU — OlO 44«-2757 




ciLPiTti. uratnu — itm 444-2757 


1 


12 
1H4 (oltcttor'a opinion that aifoably aald that tha CVP bad 




1 


13 
haaa ahla ta piovlda aqr altaiaata aatar te (load ap a 




2 


to autboiUa aottlolaat vUdl Ua pcocaotton. 




1 


aabar at poada that aaraally veald ba pcoaldiag vatatfcvl 




3 


In addltloa. It tba Ud-Tallay aaal la coaatxactad 






3 


habltata right nov, bat vbicb ara dry. ted thara ia oonearn 




4 


and If thla OOa agraasant halpa te tacllltata acaa aatar 






4 


that, aiaoa thay oan ao loagar aaa tha aalt aloogb vatar, 




i 


tbcoagb that facUlty, pachapa aeaa aaa landa aUl ba 




9 


vhic* had baaa thalt lagal aoaroa ot vatar, that thay arc 




t 


convattad toe Intanalva agclcultaxal porpoaaa. It thla 


1 


< 


having dXttloalty finding a tiaaly raplaoaaant of voter. 


7 


occoxa, thla convataloa ot land coold advazaaly attact o«»a 


1 ^ 


7 


10 It'a aort «t ironic that tba public vac 


• 


radacal and 6tata llatad ondaagarad apaclaa, aaeh aa tba 




• 


ondaratan^bly ooaoaraad aboat all tba vatarfovl tba laat 


> 


blunt-ooaad laopacd llaard. tha rxaaao kaagacoo rat, tha 


1 


• 


eoupla cd apriaga of tha laataraoa and tboaa aalanlua-ladan | 


10 


•■alaa'a haak, In addition to a aKbar of caadldata apaclaa 


1 

- 


10 


panda, aad yat va aov hava tba abaanoa of a larger aaount of 


11 


agcb aa tba tri-coiorad blackbird. 


1 
1 


11 


habiUt that Aould pcovida tor vatarfovl. mtb additions 


12 


Aara ara a o»bar ot cbarta that ladlcata tha aaoaat 


1 
1 


12 


araading »t thoaa birda, thara vUl ba laaa food available 


13 


of vatar that aay ba oaoaaaary to prealdi rallabla aatar 


'^ 


1) 


tor thoaa birda. thara ia alao tha pcoapact (ot Incraaaed 


14 


aourooa for Padaral and dtata ratagaa and tba aaaa»ant 


1 


14 


vatarfovl diaaaaaa. botaliaa aad cholera in particular, aa 


15 


araaa. Ibaaa aattaataa ara appcoalaataly 900,000 acra-taat. 




19 


tha bitda ara ooacaatratad ia Bailer arees. 


IC 


Ma ondaratand that tba C7F corrantly baa a auxplua of 


^ 


1( 


to va hope that the Departaant of interior and tbc 


17 


approslKataly 900,000 to a aillioa acra-faat. tbua, tot 




17 


ttata at Callternia vill give a aiailar aaount of concern Co 


11 


apEVOBlaataly halt of tha aatplaa ylald r^alalng la tha on 




10 




1> 


nov, va aay hava tba opportonlty to raaolva aaay ot thaaa 


V 


It 


laataraoa crlala. 


20 


ooacarna vltboot atoaadlog tba caxrant aorplua. 




10 


thank yoo vary aacb. 


21 


ted on a oondodlng nota, I'd lika to point out that 




11 


lOL ac DMIILi thank yoo. «. Ipotte. 


22 


thara la aa argant oriaia right aov aa tar aa tba abaanoa ot 


J 


12 


that' a tha one card, tba ana algnuD that I have. Ia 


23 


good gaallcy vatar tor (tata and radaral ratagaa. I ]aat 




11 


Uata aivona ■!■• that voold oara to aaka a atataant? | 


24 


talkad to tba ratuga aanagar ot tha Ian Lula lational 




14 


■all, I hata te leave ao aeon. It la early. 


1 


29 


Wildllta hafogo a fav daya back, and tb^r atill hava act 


■> 


19 


OL KSDIKCanti I'll Jaat aaka a Miort atateaant. 


J 




CMITCL UFMTUU — (flO 441-2797 




CUITCL lUOttSM — I lit) 444-2757 



127 













14 




19 


i 


1 


% ua« 14 0*1 U4 Ocknack*!, t«C[at4ry/Mu«ai o< 




1 


aia pcohlaaa that kOT* ta ba aalaad. hut I thlak thla thing 


1 


a 


Ui« UDgi Couty uuc Dlnclct. I did ut |>l4ii to sua • 




1 


that I aantad ta aaka a point on, that tha CO* aa aa noo 




1 


•UUBMt teal9ht. 




I 


haia It la a aajoz atap to pazbapa zallava tha aolutlon to 




4 


lut I thlat irhat k« 4n«IapM omi tkaaa jmtit hai 




4 


all thoa pcoUaaa that mv casa up fzoa tlna to tlna. 




S 


bMO • TacT pca«(aaalaa mai ooepacatlTa typa o< ayatas to 




S 


Ikat'a all I'd llta to aay. Out I aould auza ba In 


1 


* 


■rack out pcoUaaa that did — I saaii, tjia pcotilasa aalatad. 




t 


faaof s( aaalag adeptlan of yoaz piaaant agiaaaant. 




7 


bat t^a Bachaolca, ooopacatiea batwaaa tAa radacal 




7 


m. ac OUIB.I nant you. I notlca aa haaa too lat> 


• 


OoaacBaat aad tka Itata, <ld aot ailat to «at tbla 







atllaala. aoiild althaz cd you caca to aaka a atataaanc? 


• 


panaiMot agcaaaaat. tod aav m aas to ka«a aitUad at 




t 


la thaca aagroaa alaa that aould caza to aaka a 


10 


tUa aosavbat ooadaaion. 




10 


atitaaant? 


u 


taiaoaiily, I aould M aacy wck la faaoi of aaali>« 




11 


in« don't aa ivand a fav alnotaa than and paibapa «c 


12 


tbla Cootdlaatad Opaiatloo JlfcaaMat adoptad. 01 ooucaa. 


1 


la 


caa anwaz any gaaatloaa that you algbt hava. Aza thaza any 


1] 


!*■ alao ff« tha laa Joaqula vallay. 1 doa't tklak tha 




i> 


gaaatlona f zoa tha aadlanca? 


14 


araa that I llaa la aad tba Ud-Vallay, «tleh «aa Matlooad, 




14 


■L llOTTti Ona thing that 1 aaa cuzloua about, Ir 


19 


Md-Vall^ Caaal, tha agaodaa thara, toi aaajapia, tha 




19 


tha decisaot, thaza' a tha oootlagancy that In tboac 


U 


dlatclct ablch I as a part of. ka«a aortad lot oaai 10 yaaia 




10 


ciltlcally dry yaaza It aay ba hard to aalntaln aatar 


17 


ttylag to aort oat ooatcaeta aad additional aatac to taka 


, 


17 


taapazataza laaala that aza aaoaaaary for adaquati 


11 


cara ot ouz daplatlon. 




10 


flriMZlaa. 


!• 


na act la Coagcaaa — although thla la not tha 


, 


10 


Oaa thing 1 didn't aaa aantloaad to a graat datall li 


20 




1 


10 


aaltlpla latakaa. I'a act a Ivdzologlat, but I gaaaa the 


21 


not aoaathln« aa» that oaaa on tha boaid. If a aeaatklno 


1 


11 


naata aad rolaoa Baaa, thay algbt ba aodlflad In that aay. 


22 


that' a baan aoikad at Cot aaay, aaay yaaia. had «a hopa 




22 


had If that aazat oaaa ooatlngancy occorzad, that you oould 


23 




1 


11 


4t9m, I «aaoa« (toa tha daap vatar that la coolan and arcn 


24 


that aUl baccM a raallty. 




14 


theagk yoa had tadacad flaa la tha ttaar. yea atUl alght tx 


23 


ri« tha pcaaloaa taatlaor^, I aloo agcaa that thaia 


f 
1 


19 


abla ta kaap tha taapazatara laaar aad aalntaln aoza flab. 


Ckrmt lUOmU — (fit) 440-2797 j 




chrira. iifoanu — mo) 440-2757 


1 


1< 

m. ac uuiiiLi hob, ooBld yoa raapond? 


- 


1 


17 
lt77 aa did taka aad aa did aaa tha oapabUlty of OroaUla 




2 


m. MSKUSUi laa. Tha haiaao and othai agandaa 




1 


for tha aaUaf actlOB of cold aataz foz both tha t>o radazal 




1 


bava baan acu^ylng that pcoblaB foi a aiatoar oi yaafa am. 




1 


hatcharlaa ao that *a did aat loaa that particular crop of 




4 


had eight aoa, tha Ihdloatloaa aia that onata fu oMsalgk 




4 


aalBon. 




9 


tha banatlt that It Bight glTa to tha (lAadaa la tha 




9 


■o I do thlak that tha cocrdlnatlOD of tba tao 


4 


■actaaaoto hlvai. 







paajaota doaa alloa Ula In aaaa a drought yaar troa the 


7 


Tba aay Shaata IMa aaa ballt. It laa't aary oondaclaa 




7 


ataa^elnt ad hatchary facllltlaa. 





to gattloq dova to tha lovac daptha vbaca tha ooldat vatar 







m. ac OUIILi Ooaatlona? 


> 


la. tad taally. It aould only haka a dlKatanca — patting 




» 


■all, I da thaak yoa for ooalng, and tha coaaanta 


10 


a nultl-laaal lataka oaUat at ibaata Oaa, foe aaaapla, 




10 


that aa hara aUl ba ooaaldazad In coaplatlog tha dociaant. 


11 


voulte't naka nach of a dlffaianoa at all, according to oar 




11 


hgala, thank you. 


12 


aclaotlata. Id tha yaaca whan It* a Boat ccltloally aaadad, 




12 


laa, koza? 


1} 


aad that' a tha ccltloal diop yaata. 


Ic 


11 


W. giQIMi X notload In tba draft rapozt that thait 


14 


•o tha banaflta Jaat aian't thara. K>at ot tha yaai 




14 


la a»a aantloa ta allocata acaa of tha ooat to aatec 


19 


tha vaui taspacataza la flna. 


t 


" 1 


quality. To aa, I'a act going to talk about tbat, bacauac 


14 


ML Ifomi 1 gaaaa tha ooaoaxa la. avan though It' a 


1 


10 


all throagh tha yaaza, at laaat to tha aatant that 1 know, 


17 


atatlatlcally Iw. I gaaaa 4 paicaat, It jaat takaa ana caal 




17 


aataz guallty baa act baan a lagallaad function on tba pan 


14 


bad yaar to hurt tha caaooxoaa, Noat of tha tlna wa afa 




10 


ad tha radazal Oovaz^ot nnd tha otata to ahlch coat aay b« 


11 


tlna. hut oa tha othaf hand. U that aotat caaa ooaaa 




It 


allocatad. 


20 


trua — 




10 


»a doa't, ebaloualy, anhaaoa aataz guallty juat foi 


21 


■1. KlKanai I gaaaa I'a aaylng It aould happan 




11 


tha hack a( It, bacaaaa thaza la a<aa ultazloz aotlaa oi 


22 


aayvay alth tha BBltl-«atlata. That* a vbat ooz analyala 




11 


parpoaa at la^oalng tha aataz foz flah and aildllfa oz 


23 


ahoaa. but aa ata atlll atu^lng tha pzohlaa. 




11 


lapaaalag It foz zacraatlon purpoaaa for aalaalng ot 1 




24 


m. ■lU.IIIi I'd Ilka to add to that, irbat ao did, 




14 


laproalng It ta Incraaaa Ita uaa for Irrigation puzpoaaa. at 




19 


wa'va baan opazatlng coozdlnatlvaly foz a long tlha, and In 


-' 


11 

L 


oataza. 






CWITO. UKBTnU — IIIO 444-2797 * 


CA»IT<1. UKlTIIUi — (014) 444-2797 



128 



1 

2 
1 

4 
S 
< 
7 

( 

11 

12 
13 
14 
IS 

li 

17 
tt 
II 
10 
21 
22 
22 
24 
IS 



•o in tbaocy, I think th« lutlaaU «<t«t CoaUsalon 
■•poet — vhlch. to ■•, U 1>7>, «•• atill tba MM tai bok 
o«Bprib«nolvo toport m*t puhllriMd — 4o«s Bot cooofnlao 
mtar quality aa tha parpoaa to vkleb coat a^r ba allooatad. 

So in tkia eaaa. It thata ara — It tkata la tbat 

aoMaatlon, than 1 ra —and that* laataad* vhatavai ooata 

tbat ara raqiUrad to anbaaoa tba vatar quality ba 
«ib-allocatad to Irclqatloa ot to vbatavac otbac pvxpoaaa 
oan la fact ba aabaaaad by lapcoalaq tba «atac qaallty. 

m. MC cyufULt ion, voold you Idantlty yeoiaalt aad 
vbo yoQ rapcaaant for tba raoord, plaaaa? 

m. nDUi 1 am aoraaa ctora. 1 rapcaaant no oaa 
clgbt now. 

m. K OUIILi Xoaraalt. 

Jla, oaa you taapoad to tbatT 

IB. nnUi Vail, yaah. I voold llba to ]aat aay, 
tlrat of ail, tba Coerdlnatad Oparatlon bqra^at ttaalf 
and. aa far aa I'a avaca, tba aaviro^antal doo^antation 
doaa not nddraaa ooat allooatloaa In aiv *ayr ^apa or for*. 

■bat you nay ba aaara ot la tbat tba blU ablcb Ir. 
Iharpa nada rafaranoa to, bafora tbat ma caeantly paaaad by 
tba louaa of lapraaantatlvaa ta aatborlaa tba Saecatary of 
tba Intarlor to antar Into aad aiacata tba Ooordlnatad 
Oparatlon Aqraaaaat, baa aoBa laagaa«a wltb caipact to 
allooatlona of coat la tbat paxtloalar bill. 



arnoL momu 



(•1() 44(-27S7 



Bot tbat la not at all tba aubjact addcaaaad la tba 
Caordiaatad Oparatlon A4ra«Bant itaalf or in tbt 
anviro^Mntal doc^wntation. fba coat allooatloaa la a 
tatally ditfaraat araa tban la addxaaaad in aitbar of tboaa 
dooi M anta. 

•o abat 1 vaa intaraatad la la it you could advloa ua 
aa to wbara It waa you bad ffcttaa tba indioation that vc 
vara daaliaq with a ooat allooatioa aoanario tharc. 

m. mull I ooold do that aubaaqnantly. 

■t. VDHBIi baoaoaa that' a aoaathinq «a vara not 
■tt^^inq to addraaa in nay aaqotiatlon aaaalooa. 

IB. ■OSHklUi 10. 

IB. K nUIILi hta thara a^ turtbar qoaationaT If 
not, th* aaatlaq la adjcurnad. 

(■toraopoa, tba prooaadiaqa coacladad. ) 
— oOo — 



OmOL IDOmU — (fl(l 44(-27i7 



1 

2 

1 

4 

S 

i 

7 

• 

1 

10 

11 

12 

n 

14 
IS 
14 
17 
14 
1* 
20 
21 
22 
2} 
24 
23 



nkTi or CALirouM i 

) aa. 

ocoan or SAOuumro ) 

I, niui L. LUn, cartify that I vaa tha Official 
Court Bapcrtar, and tbat I raportad varbatia in Aorthand 
vcltiaq tba toraqoinq prooaadloqai that I tharaattar oauaad 
ay ihorthaad vritinq to ba radooad to typovritioq, aad tha 
pagaa niatMrad 1 throuqh If, induaiva, ooaatitota a full, 
troa, and correct raoord ot aald prooaadioqai 



BBTOMi Onltad dtataa Dapartaaot ot tha Intarlor 
huraau ot hacliaatlon 

OUSBi Public Baaring iti 

DBI6/I1B for tha pcopoaad Ooordlnatad 
Oparatlon Aqraaaant batvaan tha Buxaau'a 
Oantral Vallay nojact and tba Btata aatar 
Project. 

EULTli Tnaaday, Ootobar 22, 19I3 



□I arTBBSB VBBUOP. I hara aobacrihad this 
cartlticata at Bacriaanto, California, on tha 23th day of 
Octohar, lli3. 




ChPITCL BUOBTUB (BIO 444-2737 



129 



PUBLIC HeASIMG 

on Che 

DKAtr EMVIRONMEHTAi. ItVhCT STATtMnTT/WPOBT 

for th« 

COORDINATED OPEIUTIOMI ACUCMCMT 

--0O0-- 



In tha fUtc«r of: 

Stataacnts and Public Co^aan 
on tha Draft CnviroruMntcl 
Inpact StatMMnt/Raporc for 
tha Coordinctad oparatLona 
Aqraaaant batwacn tha U.S. 
Buraau of MclaMation* a 
Cancral VaUay ProjacC and 
tha California Stata Daparta 
of Hatar Raaouxca'a State 
Matar Pro3act. 



--0O0-- 
hald at 



1331 Concord Avanua 
Concord, California 



THURSDAY, HOVEKBEIt 7. I9«S 
7iJ0 0'Ct.OCI P.M. 



ll*port«d by I 

L. ROB HELLS 



APPEARAWCES 



PAMEL KPiaERS PRESENT: 

JAMES MCDANIEL, Chaimdn 
JIM TURNER, DOl SoliCLtor'a Office 
BOB BCHROEDER. Buraau of Raclamaticr 
KARL HINKLZRi Dapart*ant of Water Reaourcrs. 
LARRY MULLMIX: Dapartaent of Water Reaources 
--0O0-- 



CHROMOLOCICAL INDEX OP SPEAKERS 

— 0O0-- 

SPEAJtER PACE 

JOHN LAWRENCE, on bahalf of 
Conqraaaaan CVaocga Millar . . . 

LORI GRIGGS, on behalf of 
Suparviaor Sunne Wright NcPaak, 
Contra Coata County . . , 



JOHN DIVITO, Board of Oiractora, 
Contra Coata Water Otatrict. . . 

LAURA KlNC. Natural Raaourcaa 
Dctanaa Council . . , 

WILLIAM DAVOR£N, Tha Bay 
Inatltuta of San Franciaco , . . 

DAVID OKITA. on bahalf of 
Contra Coata County Board 
of Suparviaor*; To* Torlakaon, 
Suparviaor . . , 

TOH CHATF. EDF . . . 

FREDERICK BOLD, Junior, 
Counaal, Contra Coata Water 
Diatrict . . . 

Canaral Quaationa and Anawara 

Stacamenc by Suparviaor Toa Torlakaon, 
Contra Coata County Board of 
Suparviaora . . . . 



Attachaant 



THURSDAY. MOVEMBER 7, I»8S, 7 1 30 O'CLOCK P.H. 
OOMCORO, CALIFORNIA 



MR. HCOAMZELi Okay. It wa could gat atarted 
Ha'd Ilka to «f«lco«a you all co tha aacond aaating on 
tba Knvlronaantal I^act Raport, Environrantal lapact 
Btataaant (or tha Coordin«tad Operating Agraancni. 

Bafora w gat tha ■a«tlnq atarted, I would like 
to introduce the head table. To my right, your left. 
wa bava jia Turner with tha Oapartaer.-. of Interior 
Solicitor'a office. 

Wa have Bob Schroadar wiUi tha Buraau of Reciamatior. 
tlia iacraaanto Region. On ay left la Larry MuUnix. He ' a 
a dlviaion anginaar with tba Oapart^nc of Wacei 
■aaourcaa. Division of Oparationa. Wa have Karl hintiiei 
Ha work* with tha Central Diatrict. and ha ' a the peraon 
who'a raaponalbla for putting that docuncnt together. 
60 if you have coaplalnta about the length of it. I'd ii>t- 
for you to diacuaa It with hia and not ate. 

Tha purpoaa o( tha aaatinq la to receive coanencs 
on tha Joint Bnvirona«ntal lapact StataiMnt/Environaantai 
lapaet Raport on tJia propoaad Coordinated Operation 
Aqraaaant for tha Central Valley Project and State water 
Pro)act. 



130 



Thtt ■••ting la Mlnq rsoordad and tha procaadingi 
will b« siuMarliad. 

Th« purpo«« of thli MAatlnq la to haar your co^aanta 
on tha doci^wnt. Uowavar, wa will ba taking wrlttan 
en— anta, and anything you cara to add or glva ua in 
writing t#a will racalva; b« taking thoaa cooMnta through 
Hov*Bl>«r 3rd of thia aonth. Hovaatbar 13th, !*■ aorry. 

How, tha raport that wa'ra going to ba dlacuaalng 
thia avanlng axplalna tha purpoaa and objacttvaa of 
tha draft docu»ant, which ia to avaluata tha anvlronaantal 
conaaquancaa of tha propoaad action of aigning tha 
Coordinatad Jtetion Agraaaant and tha altarnativaa to that 
propoaad action. 

Tha procaaa atartad in a aariaa of acoping 
•aatinqa that wara hald throughout tha Stata during 
Auguat of 198 3. 

Since that tiaa a nxaibar of public nagotiatlng 
aaaaiona on tha agraaaant wara coaductad. Thia occurrad 
during 1984 and 198^. 

Tha oagotiatora raachad an agraaaant Movaabar 20, 
198S, and wa coaiplatad a draft tIS/EIR in Saptaatoar and 
diatributed it at tha aaaa tiaa. 

Tha public raviaw parlod anda on Movaabar tha 13th, 
198S. and thia ia tiia aacond aacting that wa'va hald on 
tha docuaent. 



24 



the only thing I'd Ilka to aay ia that thia la a public 
hearing or aeatlng, principally on receiving ooaaaata 
on the EIS/EIRt on tha envlronaMntal iapacta of tha CQA, 
not a hearing or aaeting on tha COA itaalf or the 
propoaad legialation. 

Certainly we'll ba happy to receive any co^aanta 
that you have, but we'd like to apand »» awch tiaa aa 
we can getting your thoughta on the environaantal iapacta 
of the COA ratner than aoae of theae other related aapecta 

Nil. MCOAMIEl.: Thank you. Larry? 

HR. MULLMIX: I really don't have anything aore to 
add. I think we ought to liait that to that regard. 
What thia hearing ia for ia on tha EIR and BIS. 

HK. HCOANIELt Okay. With that we'll gat 
atarted. To lead oft wa have John Lawrence rapraaanting 
Congreaaaan George Millar. 

John, would you proceed? I gueaa I didn't give 
you tiaa to gat prepared. 

Hit. LAHRZNCEi Uaually we atart thinga lata in 
Haahington. 

Nr. DaVito la handing out a copy of a atataaant 
by Congreaaaan Millcc. 

My naaa ia John Lawrence. I*a Congraaaaaa Gaorga 
Hlller'a adainiatrative aaalatant In Maahinqton, and 
]*a appearing hare today on hie behalf. Ha'a atill in 



\l » 



3 

Hrtttan coaaanta and coaventa received at this 
and tha Sacraaanto aaeting will be incorporated in the 
final docuaeot and a Motica of Deteraination will De 
filed with the Dapartaant of Water Raaourcei and « 
■•cord of Daciaion filed by tha Bureau of Reclamation. 

Ha expect tha procaaa to ba completed about January 
of next year. 

I aiqht tall you how we're planning to conduct 
tha aaeting. You were aakad to aign a card it you care 
to aake a atateaent. and I do have half a dozen carat at 
the preeent tiae. 

He'd aak you, if you have a lengthy atateaent, if 
you would pleaae auaMariae eo that wa give everyone an 
opportunity to be heard. And at tha end of the period 
we will take a few ainutea and answer any queation& 
or at leaat attaapt to anawer any quaationa any of you 
aiqht have coocarning either the docuaant or the 
procaaa it want through. 

■afore wa get atartad with tha atateacnta, we 
will have a brief atateaent froa the Bureau of Reclamation, 
and Bob Schroadar will be aaking that atateaent. And 
I^rry Nullnlx will ba aeking a brief atatament fron the 
Dapartaant of Hater Rasourca&. 

Bob, with that, would you proceed? 

MR. SCBROeoERi Tbanka , Jia. I think really that 



Haahington. The House of Repreaentatlvea la in aaaaion. 

I'll aova through this atateaent, reading aome 
and au^uriiing other portiona, and then if you have 
■pacific quaationa or coaaMnta. I'd be glad to reapond 
to thaa. 

This draft Environaantal Impact Stataaent la on the 
Coordinatad Operating Agraaaent, a critical agreement 
for paopla of thia area, in particular. Contra coatd 
County and tha entire Bay Area 

The aqreeaent provides a framework for th« 
aanaqaaant of Stata and Federal Hater Pro]ectB ani 
aaauras that both pro]ecta at laat are conaitted to the 
protection of Delta water quality. 

By guaranteeing Delta water quality, tnia agreement 
can help to and tha water wara and relieve the legitlati-.- 
paralysia which has long crippled our state 

Thia will benefit all Californians , north and eouth. 
and thoae in the Central Valley, Southern Caiitornid a 
the Delta aa well 

Thia agraaaent ia an hiatorlc one. />rd it im sr 
■weeping that the Congreaa haa, on a regular basis. 
reviewed Ita provlaiona to aaaura that it la txjtr 
fiacally raaponslbla, anvlronaentally sound, and 
adalnistratlvaly feaaible. And I think that it woul.: 
ba appropriate at thia point to aay that aa Congreaaaan 



131 



Hlilar has aatd to th* lndlvidu«l wmmbrnzm of Uto 0*p«r*««nt 
of M«t«r Koaourcoa and tha Buraau in tlM paat, that 
wa ara vary qratoful tor tha attantion that you pa 'pla 
hava givan, tor tha prolaaaionaiia*. (or tha atr jntlvanaaa 
to tha concarn of tha paopla in Contra Coaca ''ounty and 
tha Dalta araa in ganaral In tha davaiopaan of thia 
Coordlnatad Oparatlng Agraaaant. 

Tha Itouaa of Rapraaantatlvaa har aiao paaaad 
laqialation, HR JllJ, Introducad by ''onqraaaaan Mlllai 
CO aandata tha protaction of watar quality In tha Dale* 
and to authoriia tha Buraau of f-aclaaatlon to antar Into 
tha Coordlnatad Oparatlnq A^rvaaant that It tha aubjact 
of thla haarinq tonlqht. 

Ma ara hopatul that tha fianata will act on that 
laqialation In tha naxt faw waaka, and wa would nota that 
botli of our Scata Sanatora. Alan Cranaton and Pata Hllaon, 
hava andoraad paaaaqa of Conqraaaaan Nlllar'a laqlalatlon 
in ica currant tors. 

In addition, a wlda array of divaraa and uaually 
antaqoniatic Intaraata t&rouqhout our atata, including 
cite Hatropolitan tfatar Oiatrlct, atata and fadaral watar 
contractora. and anvironaantal organliatlona, aqraa that 
HP 3113 la a 'paaca traaty' which ahould torn anactad without 
f urthar dalay 

ftacauaa tha lagialatloo that Conqraaaawn Millar 



conatruction of additional unlta of tha Cantral Vallay 
Pro}acc . 

Tha tallura of tha Day and Oalta araa to hava 
chaaa lagitiaata daaanda raeoqnltad by watar plannara 
in Che paat haa lad to tha ragional confllcta and 
atalaakataa which hava la]urad all Californlana. 

Tha laqialaclon obligataa tha Padaral Govarnaant 
to aaat Btata watar quality atandarda foe tha Dalta and 
tn« Bay, indapandant of tha Coordinatad Oparatlona 
Aqraaaant itaalf, «a a aaparata aattar of law. It 
ahould ba claai why wa hava choaan to do thla. 

It la aiaply lapoaalbla for tha Fadaral Govarnaant 
to. on tha baata of an aqraaaant which can ba vlolatad 
or which can ba abrogatad at any tiaa, to go forward 
and aign loag-tara watar aarvica contracta or approva 
tha conatruction and oparation o( aa)or watar facllLtiaa. 

Ma naad tha aaata quarantaaa ovar long parloda of 
tiaa that tha paopla who will banafit fro* thoae 
contracta and tboaa projacta will. Tharafora. It it 
aiaply not anough to hava a Coordinatad Oparatlng Agtaaaant 
that aaauraa that Dalta watar quality la to ba praaarvad. 
It la nacaaaary to hava that aa an Indapandant matcar 
of law. and thac ia what Congraaaaan Mlllar'a lagialatlon 
will do. 

Tha lagialatlon provldaa an additional aafaguard 



haa latrodueod and which tha Kouaa haa already paaaad is 
•o critical to tha lapiaaantation of tha Coordinated 
Oparatlng Agraaaant, nm wanta to aaka aavaral atataaants 
to clarify Ita intant and ita ralationahip both to the 
agraoaant and tha Cnvironaantal lapact Stataaani . 

Moat alaply, thia bill authontcs tha Sacrecary 
of tha Intarior to axacuta tha Coordinatad Oparatinq 
Aqra^aant, which la an appropriate action given the acou< 
and breadth of thia aqraeaent 

It diracta tha Sacratary of the Interior tt 
oparata tha Cantral Vallay Project to neat the atandaros 
(or tha Dalta and tha Bay aa aatabUahad by tha State 
Matar Baaourcaa Control Board. 

He ahould nota that tha laqialation that haa been 
paaa*d by tha Houaa o( Kapraaantatives. in addition, 
raquiraa cartaln chAngaa in law and tha propoaed 
Coordinated Operating Agraeaant which ara aaaantial to 
aaaura that Ita intaodod purpoaea ara net - 

Tfkoae of ua in the Delta, whoaa watar quality has 
deteriorated aa a raault of tha axporta of tha two 
pro]acta, tha Btata and tha Padaral Mater Projects, 
the Oparatinq Agraaaant and Ita iaplaaantinq leqialatior. 
auat provide a vary (undaaantal and a very baaic aaaurance . 
That our watar quality will not be undcralned through the 
algnlnq of n«w watar dallvary contracta or with the 



to tha 350.000 cuatoaara o( tha Contra Coata Mater 
Dlatrlct -- and it'a a good thing it doaa here tonight -- 
whoaa only aourca of drinkinq water la tha Dalta. 

Thia laglalation qu«rantaaa in federal lew that 
apaclfic water quality atandarda, at laaat aa good aa 
thoas eoatalitad in IK14B&. will be Maintained at the 
Dlatrlct'a intaJie. 

Tha COA allowa the Padaral Govarnoant to enter intc 
contracta Coc tne conveyance and purchaaa of Central Valley 
project wetar. Me believe that chaaa contracct conatitute 
a vary alqnlficant departure (roa paat practicaa. And 
while wa do not theoretical ly object to thaa, wa do not 
believe thay ought to be approved ainply by adainiatracors 
without adequate public review or review by tha Congraaa . 

Ma ballava that the Congraaa, which au'honze:: 
tha project, auat nave an opporcunicv to examine tne 
conformity of tbaae contracta with aandacaa laid dowi. 
In federal atacutaa governing the utilisation, sa r 
and developaent of federal watar. For chat raaaon. HR 3UJ 
requlrea Congraaalonal approval of thaaa contracts 

Blallarly, tha bill provldaa that the Sacratary 
aa,' not teralnata the Federal Govarnaent'a participation 
In the Coordinated Operating Aqraeaant without (Irat 
aubalttlng to the Congraaa a report outlining hia raaaoni 
for doing ao (or a period of 180 daya. Ma alaply cannot 



132 



10 

Allow A BituAtion wh«r« th« co^KitJMnt of th« Psdecal 
Govarnscnt to protect th« D«lt« raats lolvly on an 
«gr««a«nt which can b« violated at tha wbin ot the 
Sacratary of tha Intacioc, 

Tha Coordlnatad Oparatin^ AqraMwnt will allow for 
battar planning and coordination, but it obvloualy cannot 
pravant ahortaqaa that aay occur — and In all likallhood 
will occur — in tha aaount of pro)act watar available 
to seat contractual coaaitnanta and Stata watar quality 
atandards 

Whan Bora ahortfalla do occur In tha future, 
thia lagialation *andacaa that the Secretary reduce 
deiiveriea to all uaera in order to aeet Delta water 
quality atandards. 

Tha firat raaponaibility for enduring thoae 
reduction* will coaa froe agricultural contractors 
before reductions are lepoaad on aunicipal uaera who 
lack available alternative aourcea of water for eaaeatial 
hLiman health and aafety. 

Juat as policy euat coaa before pluabing, p*ople 
Buac co»a before plants. Thia la the basia upon wbich the 
project has been operated, with the cooperation of 
all partiea, and we believe that it ta a aound basis 
for future operaciona aa well. 

The legialatlon alao requires that water aold 



12 

Action* option la an option that we cannot afford. 

We have already aeen the evidence of what no 
action will produce. This year we've read the reporta 
of historically low baaa counta and other fiah populationa 
have been decimated, and we have no assurance that 
drinking water auppliaa will not grow worae . 

He cannot live with that uncertainty in thia 
county and that'a why the COA and BR 311) are urgently 
needed at thia time. 

The COA will not solve every watar policy problen 
tacing California. The aclenit^ crisis at Kesteraon 
Reacrvior , which is the direct result of irrigation 
practices, illustrates how serioua and unpredictable 
future challenges will be. 

The truat and cooperation which haa produced the 
consenaua behind HR 3113 and tha COA will be aaaential 
If wa arc to avoid falling back into the suspicion 
and regional diviaion which haa long characterised 
wacar policy in thia state . 

The COA and our legiolatioa are leaaona for all 
of us in tha right way to Kaka policy deciaiona on aajor 
policy laauas: In the open, with full public participation 
and review, and with a cosasitaant to tboaa 9oal* which 
aerve beat the Stata as a whole. 

He believe that the tiae baa coe« to aove forward 



under future contracta. that a portion of tn^t water 
be recallable, in the event that additional 
atandarda are lepoaed by the State for the Dcic« cr 
the Bay . 

Surplua water will reaain available foi sale, ai> 
in the peat. tut water which ia needed to meet lawfully- 
eatabllahed kay-3eita water quality standards is not 
"Burplua' and euat be available through thia lecd, . 
■BChaniae to seat thia funda«entax project purt-oke 

Tha BIS reatfirea the co^itmenc to Delta wate^ 
quality, which ia tha central tenet ot HP 311J and the 
Coordinated Operating Agreement itseil 

In fact, the eiS iMpilcitly concludea that if we 
tail to ratify thia hiatoric agree«ent, water supplies 
throughout the Stata and water quality here in the Delta 
will undoubtedly suffer end deteriorate. 

If we fail to act, the CIS notea, salinity in 
Delta channela could laveril not only our drinking water 
auppliea but the feraing and the induatrial activities 
which provide thouaaoda of )oba and proaota the economic 
vitality of the entire hay Area. 

Under the 'Ho Action' option, salinity, THMs. ana 
other cODtaaunanta would jeopardiie the water aupply 
of hundreds of thouaanda of Contra Coatans and others 
in this area. For that reason we believe that the 'Nc 



1 


« 


i 


i> 


m 




i 


14 



and to end the suspicion and the stagnation which has 
ii^wded sound water policy in thia atate for far too 
long. 

TtM COA, the legialatlon, tha EIS that we're 
testifying about tonight provide the fraaework for 
acc^spllahiog that goal. And we urge the Bureau and 
the State to proceed with their approval tor this 
docisant. 

Hit. NCDANIEL: Thank you, John. Next, we havt 
Hias Loci Griggs. She repreaenta the CoflBittee for 
Hatsr Policy Conaanaus 

MS. GRIGGS: Thank you, Mr. McOaniei. HeBbere 
of the hearing penal, I'e here thia evening repraaentir 
our coaaittae chair, Superviaor Sunne Wright. McPeac. 
who IS a supervisor fro* Conta Coaca County. Sne 
regreta that she ia unable to be here thia eveninq 
to provide this atataMenc in peracr 

I aerve as project director for the Coasittee 
for Mater Policy Conaansus, and we're very appreciative 
of the oppurtunity to teatify before you this cvenint^. 

The Coaalttee for Mater Policy Conaenaus la a broad- 
baaed and balanced group of diverse interests froe the 
12-county San Pranciaco Bay-Delta srea, a region that 
ia hoae to aeven adllion people. 

This CO— ittee of public and private leaders 



133 











1 


^ • 1 






14 
Includa* alvctAd o((icl«la. r«pr«»«ntatlv«a froa 


1 




doaa not co«it tha Padaral Covarnaant to ■eating 






bualn«a«. tnduatry. latmr , wat«r a^anclaa. •nvlron^antal 






future water quality atandarda aat bv tha State Water 








and public Intaraat orqanlsaclona, aqricultural lotaraata. 


1 




Baaourcaa Control Board. TUe COA only obliaatea the 








tri« acadaaic cosBunity. and Individuals with watar 






O.B. Bureau of Bacla»ation to aaeting tha currant 








raaourcaa axpantac 






atMdarda aa contained in the State Board'a Daemon 1485 








Tha prljury purpoaa of tha CoHittt*« whan it 
otqanitad tn 198} Maa to davalop a watar policy conaanaua 


' 




Tneae atandarda are aspactad to change within • few 
yaara. Havertheleaa, tha COA aaauredly rapreaanta a 








that raflacta aconosic afflclancy and anvlronaantal 






atep In t»» right direction, and we wiah to coaaend the 








protaction . 






efforta of tha federal and atate necotiatora in bringiro 








Tha Cn— Ittaa tor Watar Policy Conaanaua la 




<0 


about thii hiatorlc agreeneVic. 




B 




atrongly co^ittad to a*curin9 protactlona for Wortharn 




• 


i 


It auat be noted that wa do have aowe concernt abouT 




Si 




California and for tha San rcanciaco Bay-Dalta raqlon 






h " 


tha draft EIB/EIS for the Coordinated Operation Agreemeni 






bafora thara la any incraaaa in tha laval of axporta 






11 " 


Our aaior concern focuaea on tha aeaumption in the EIB/E1£ 




h 




out of tha Oalta. 




• 


it ,. 


that the Declalon 1485 watar ouallty atandarda proviot 








Mm aaa tha Fadaral-Stata Coordinatad Oparatlon 






3 " 


adaquata protectiona for tha Bay-Delta aatuarina ayaten 








Aqraaaant aa balng a critically latportant ftay-Dalta 


1 


i« 


It la clear to ua that tha Deciaion 148S standards 








protaction Maaura. W« aupport both tha CQA and Hff 3113, 


« 


17 


do not adequately protect tha Bay-Delta aatuary. The 








authoriiing tha Sacratary of tha Intarior to Hqn tba 




It 


borrendoua decline In the Striped Baaa Index la co^wiling 








COA. 




It 


evidence of thl* 








wa'ra axtraaaly plaaaad that tha r*daral 


• 


» 


The Stete Board aet a goal in 1978 tor a Stripei 








GovarnMant, throu9h tha COA and IR 3111, nov haa sada a 




n 


Baas Indaa of 79i the index haa declined precipitously 






22 


coMiitaant to providinq ita ahara of watar quality 




n 


to »,4, a level even lower than during the 1976-77 






23 


protactiona for tha San Pranclaco Bay-Oalta aatuarina 


- 


» 


drought and, in fact, tha loweat point in tha history 






24 


ayataa in accordanca with atata-^ataraioad atandarda. 




M 


of tha Index 






23 


Ma ara coocarnad, howavar, that tha COA itaalf 




a 


Tbia situation la not acceptable, and Oeciaion 








16 
149S auat ba Modtfiad to inaura tha baalth of tha atripad 




1 


17 
Tbe BIS/BIR abould include an analyaia of the 








baaa aa wall aa othar fiah and wtldllfa In tha aatuary . 


'_ 


1 


baaaflta to tba Bay-Delta aatuary If this aaount of water 








Additionally, Oaciaion 14IS doaa not includa 




> 


was uaad to laprova water quality In the aatuary -- 








adaquata atandarda for Sulaun Rarah, San Pranclaco Bay. 




4 


above Daciaion 148% atandarda — by allowing tha water 








and tha South Dalta. Thaaa inadaquaciaa ahould ba 




t 


to flow through and out of tha Delta rather than bcinc 








notad in tha EIS/CIR. It la wrong to aay that by aiav>ly 




t 


•ada availabla for export out off tha Delta. 








■aating oaciaion 148S atandarda. tha Bay-Dalta aatuary 




7 


Me ahould aota that tha economic dSMsge due to 








will ba protactad. 


1- 


t 


loaaes in the stripad baaa, Chinook aalaon, and ateelheac 








Ha aiao note that Daciaion 14t& waa rajactad 




t 


trout. Central Vallay fisheriea aaiounts to S117 ai.ucr 








by the Superior Court aa laproparly proKulgatad. If 


1 


10 


a year, with an additional loaa of SIJO xillion ir 




s 




tha EIS/EIR la to aaka tha aaauaiption that Daciaion 




w 


B 11 


racraation banatita. 




Xc 




MBS adaquataly protacta anvironaantal valuaa, than 






\i " 


Tbase are loaaea that will ba auffered annually 




si 




detailad inforaatioo ouat ba provided to docuaant tha 






|: » 


aa long as thaaa three fiahariaa remain at thair current 








validity of thia aaauaption. 




^ 


dapraaaed lavela. The aource of this information a 




s 




Additionally, tha BIS/EIR ahould hava aora 






3 IS 


a report prepared by Mayar Raaourcea tor the CaiitorniA 






l« 


infocaation on tha aftact on San Pranctaco Bay of 


1 


IB 


Department of Piah and Gan^r 






ir 


divaraiona aada by thaaa two aajor watar projacts. 


1 


17 


Another auggascion tor the EIS/Elft la that ar 






t* 


Information on tha atfact on tha aatuary of raturn flowa 


1 


It 


analyaia of tha varioua methoda by which t)ie COA can oe 






!• 


troB agricultural waatawatar dralnaga (ro« tha San Joaquin 


' 


f 


terminated, either unilaterally or by botn partie? 






10 


vallay alao ahould ba Includad. 


' 


m 


ahould be provided. There appears to ba several ways Coi 






ai 


Tha COA provldaa for approsiaataly 900.000 acra-faat 


1 


]i 


the two partiaa to terminate tha agreement 






22 


of watar to ba mada availabla froa tha Cantral Vallay 


1 


a 


Generally, thia concludaa our general connents 






» 


Pro]act aftar axacution of tha agra^aant . Ttoa draft 


1 


a 


on the draft BIS/BIB. 2 have a few additional specific 






24 


BIS/BIB diacuaaaa poaaibla uaaa of thia watar. including 


' 


>4 


co^Mnts. TtMsa ara In writing. I think I will give 






39 


aala to othar contractora. 


1 


» 


those to you In the written record. 










» 







134 



IB 

But I would lik« to know about ona of th«« and 
that la a concarn that la raiaad whara on paga 14 of 
tha docu»ant, thare ia a ahort dLacuaaion concarninq 
rrlant Daa and Millerton Laka . 

Priant Da« la locatad on a atraaa tributary to 
tha San Joaquin Rivar. Tha San Joaquin Rlvar la ona of 
tha ■ajor tributariaa to tha Dalta. fcn axpLanation abould 
ba aada aa to why watar divaraion facilitlaa on tha 
San Joaquin lUvar, Buch aa Friant Dan and Maw Malonaa 
Dan. ara not govarnad by this agraamant and why thay 
ara not axp*ctad to contrlbuta to Bay-Dalta watar 
quality . 

In concluding our raaarka on tha draft CI8/CIR, wa 
note that wa will Bonitor with Intaraat tha prograia 
on tha Coordinatad Oparatlon Aqraasant . Ma look forward 
to tha Caderal-atata partnarahip in protactlon that la 
rapraaanted by the Coordinatad Oparatlon Agri— ant. 

Ha thank you for thla opportunity to ahara our 
concerna and auggaationa with you. 

I'll giva you tha wrlttan atataaant . 

HR. NCDANIELt Ha will now call on John MVtto. 

MR. DEVITOi Thank you. Kr . Chairaan and Haabcra 
of tha Panel-- 

KR. MULLMIXi Thank you for tha uaa of tha hall. 

MR. DEVITOi Lat aa )uat aay that batwaao tha 



n 

33 



20 

plant, but wa laava to tha whuu of natura to provida 
you that water.' 

It i« for chat raaaoo that thla Oiatrict ainca 
tha ' SOa haa aougtit a aiaipla ■■andwant to tha Padaral 
Central Valley Project Act of 1937, which actually than 
would cauaa all tha rivara of tha State of California 
to operate by the aaaa eat of rulaar tboae owned by 
the Dapartaanc of Hater Reaourcea aa well aa tha Bureau 
of Raclaaation. And wa have a atate-wlda intereat in that. 

He conaidar the Delta aa tha watar croiaroadi 
tor tha entire State of California, and when we look at 
CongraasMan Miliar'a bill 1331 which taplaaanta tha 
Coordinated Oparationa Agraeaent •- and thia waa part 
of By teatiaony before Congreaaaan Hlller'a coaelttee 
In uashlngton — )uat look at the nuabera, your nuabara, 
the oepartaant of Hater Reaourcea/Buraau of Raclaaation. 

Tha Bureau of Reclamation and the State of 
California axporta 86 percent of the watar within about 
alK ailllon acre-feet in '11 and and average of sis point 
two ailllon acra-faet per year. Eighty-alx percent of 
that water qoca to tha San Joaquin Valley. Ten to twelve 
goea over tha Tahachapia. 

My teatiaony In Haahtngton aaid the Lyona, 
Coelho, Lahaan. and Beehan need the hlghaat watar 
quality in the Delta becauaa they ara the aa]or xaportera 



19 

Bureau of Raclaaation and the Departaent of Hater 
Baaourcaa. wa are a coaaitted aaaber to your fa»ily. 
you are welcoaa to uaa tbia facility at any time. 
He ara honored to have you here. 

My naae la John DeVito, repreaenting tha Board 
of Oirectora of the Contra Coata Hater Dlatrlct. And 
X waa r«alnded that on July lOth. and I waa here at 
tbe tlaa, l»57, Clyde Spencer, Regional Director of tht 
Bureau of Raclaaation, eent correapondanca to Harvey 
Banka, Director of tha Departaent of water Raaources. 
and Clair Hill, Chalr^n of the California Hater 
CoiMieaion, saying that wa conalder tha obligation 
of the central Valley Proiact fulfillad by aiaplv meetin. 
tha atandarda of the Hater Rtghta, Tracy Puapa. tnt 
eschange contractor, and Contra Coata Canal, 

However, ahortly thereafter in teatiaony betorc 
tha then State Hater Blghta Board and later tha State 
Mater taaourcea Control Board, the Bureau of Reclamation 
aald, "Ma have no obligation to provide water of the 
quality auitable for H(I uae for tha Contra Coata Water 
District other than that which occurred abaent the 
project." 

in other worde. Secretary Cecil Andrew, said. 
"Me take your aonay for lUl water auitable for MH , 
that'B »» Delta aarviea charge plua Intareet on capital 



21 

of that water supply, if you take care of the Lyons, 
Coelho — Congreasatan Tony Coelho , Congraaanan Ric*' 
Lehnaa, and Coogreaaaan Chip Beehan — who import 86 
or export froa tha Delta 86 percent of tha aupply — and 
they need that water for tha health of tha aoila of the 
San Joaquin Valley, the aalt balance, the health of 
the plant life, and certainly the econoaic health of 
the Valley — if you take care of tboae healths of the 
Valley, with the 86 percent laport to the Valley. yo>, 
will autoaatlcally take care of Congraasaan Hiiler's 
2 percent of export or Import froa tha Deitd 

Let aa atraaa that over and over again, that n 
la tha entire area aouth of Tracy that benefits moi-. 
froa good watar quality -- along with ua, of course. 

It la not a aingular benefit to thia area. 

May I addraaa tha CIS/SIR proccas? I have ^ 
little difficulty with thia. Vour propoaed actior, 
aaya we're talking about an CIR/EIS in terma of execution 
of the COA draft, the one dated 5/20/6S. 

Z really feel that tha action that you ahould be 
dealing with la iaplementation of Congraaaaan Hlller'a 
3113. Let ^ explain why. And again, I'a going back 
to my teatiaony In D.C. 

If you take the COA In itaalf. it ]uat do«i not 
Btand. It haa too aany aalf-daatructa in it. It's 



135 



• •auBpclooi. I aon't tliln«. .m .una. 

for .ui«,l., I, „._, thtt Mlu teclilon 14iS 
•111 Ho oruia Uilii9> In una a( tb* tayixua 

• •cuacln. .„t«. I, j„t «»•«. If. M iBfri. 
•olutloi. In Ul. drat placa. It'a an liico^,l.c. 
aolution. In otKar .ratda. it doaan't avan ,o to tha 
»My. That .111 COM into tha haarlnfa out of tha »ay- 
Oalta rian. tad (urthaiTaora, Ifa Inadaquata 

Lat •> ]uat aantlon, fcoa July 15 Urou^li Uprll, 
Contra Coata Canal Intaka la controlUn,. It eontrola 
at liO parta chlorlda. rou<)til» JOO TM . Ttiafa unfit 
for nuun baalth. lor «inlclpal and Induatrlal ba.ltji, 
and cartainl, «ot tna aoU haalth, and plant Ufa haaltn. 
of tha .allay, thafa tha lnad«,uacy of that particular 
d«ciaion. 

riutteiaora. tha Coordlnatad Oparatlon Mrauant 
if al9nad and If authoriiad atrlctly aa that unit actually 
authontaa on* aat of atandarda. 14tS . ABd If you look 
at Saction U, tha lacratary can vary aaally aay that 
in tha abaanca of Congraaaaan miUr-a bill chat Ifa In 
conflict ,1th tha dlr«:tl«. of tb. Congra... Aivl thafa 
tha and of tha COA , 

If you look at tha aalf-daatrucc faaturaa of 1«|] 
•hara althar al,natura. tha Sacracary ot tb* Intarlor or 
th. Dlractor ot tha DapartMnt of Katar Haaourcaa. can 



pro]*ctlona and wa can raly on It. 

finally, and aqain, in ballav* tha Ilt/lII ahould 
ahould daal >ltn a propoaad action not llaltad to tha 
a.acution of tha COA, which cannot atand on ita o»n, 
but a raauthornatlon ot tha Cantral vallay rrojact 
• a anvialonad and intandad undar nil 111) nhich will, in 
lact, tor tha firat ti>. in hlatory cauaa all th* rl.ara 
of tha st.ta ot Calilornia to oparata undar ona aat of 
rulaa tot tna banatit of aoatly tha Vallay and tha 
Tahachapi araa. Thank you. 

l«. KCDAMIEL. Thank you, John. M* will b* 
happy to .aat with your ataft at any tta*. ihould w. 
call you ot would you Ilka to call ua7 
M». OCVITOi Ka'U call you. 
M». WLmiXi It will ba toKrrow, I bat 
KM. KCMMICL: Halt, I'll Call Laura king. 
MS- IINCi Good avanlng. I<* Laura Ring. I*a 
a ataft aclantlat with tha aatural kaaourcaa Dafanaa 
Council . 

IlkDC bollavaa that tha COA la a bl« atap forward 
and tha tha Fadaral CovarnMnt la aqraalng for tha flrat 
tl*. to ••*t Stata Katar Quality atandarda for tha Oalta 
and tha lay. Protactlon of tha Oalta and tha lay ar* 
claarly na^ladi It'a an l.|>ortant goal. And wa thlnl; 
that tha COA la an Important atap In tha right dlractlon. 



li 
walk away froa that agra«aHnt dua to ona raaaon or another 
That la aaothar aalf -daatruct , If you ]uat take a look 
tha COA within Itaelt. 

1 coaM back again to that vary, vary laportant 
critarla that tha laplaaantatlon of HA 3113, which is 
In fact a o*w dlractlva of tha Congraaai it can't be 
In conflict ala^ly b*cauaa th* Congraaa la aayinq to tne 
■uraau of RaclaaMtlon, 'Thou ahalt oparata tha project 
to tb* ■**t th* wat«r quality scandarda for tha Bay-Oeltd 
aatuarin* ayatas aa laid down by tha Board tron time t. 
tlM. * 

That la a lot dlttarant than narely havino a 
COA. Than, incidentally, it aaya, 'Thou ahalt impienent 
a COA in ordar to d*v*lop an oporational plan.' 

I'd Ilka to. for cb* r*cord, ask that wa be allowed 
to provide you with a written atatasMnt prior to your 
data of Hovaaber 13th. I'd Ilka to have ay staff eeet 
with your ataff. Tliere are aoae technical problems that 
we have . 

One of th* Major onea la your water quality 
projections aethodology. tad thla Is soaethlng that 
w*'d Ilka to bring the Aureeu of Raclaaation and the 
Oepartaant of Hater Reeources into a co«K>n area of 
■ethodology trtMre you all have a aura faith, a poaitive 
faith that it's going to bappan in tareia ot your 



25 



but w. do have several coocema with tha COA, in 
particular for purpoaes of dlacuasion tonight with th. 
>I>/EI> on tha COA. 

In m<m. the three concerna are: Firat. the 
e«cut.o. Of the COA la likely to trigger the aignino 
of >any new contracta for cvp water. Tha «>ratoriur 
on new contracta upoaed by Secretary Andrewa in tn. 
!»'• will be lifted once the COA has been eigned 

"e'r* concorned that all of tha water, all of 
the aurpiua water available, a^da avail.bl. under the Co* -- 
the 900,000 additional acre-taet - will be contr.ctea 
away before any ,a aat .aide tor wildlife refuge, wne,. 
it la badly needed. The Els doe. not address this 
lapact . 

Tha aecond concern la that wn.l. ,o.» env.rcnmenta , 
b*n.fits will raault fro. tha COA, it will also h.v, 
ao.e .nvlron-ntal-ha™iul conaaquanca. , which the 
• lA/EI. docueents. But th, EIS t.us to propose ..t.gat. 
•eaaurea to alleviate theae advarae ..pact.. 

The third has been addreaaed by a previous speaker 
The EIS does not addreaa the deflc.enci.a ot th. ex.atin,, 
0-14I5 Delta Hater Ouallty Standstua 

"o«. I'd like to elaborate Just a little bit on 
each ona of these points. 

The EIS/EIE adalts tha. tha -.rator.u. on nev 



136 



25 



2( 

contracta will b» lifted aftar tha COA i* algnad. but 
It teaan't analyia tha aavlronaantal conaaquaacaa of 
thla dlract raault of al9nln9 tha COJt. 

Aa tiM pravloua apaakar aald. about an additional 
•00,000 acr*-faat will ba atada available In tha Off aa 
a raault of alffnlng tha COA. It aounda Ilka a lot 
of watar but not wban you conatdar tha ooaipatln« daaaada 
for that watar. 

Tttm Ouraau aaya that it baa lonq-tara obll9atlona 
(or aavan point ona million acra-faat, wtkax«aa« rlqht 
now It 'a dallvarlng about alv point two Civa Billion 
acra-faat. That aounda Ilka to aa that th«y hava alivady 
got plana to dallvar all that axcaan watar. 

But tha Flah and Hildllfa Sarvlca baa i ii nawiiiiliil 
that about half a alilion acra-faat ba aat aalda for 
wlldlifa rafugaa. Ha think that's •oaMthlng that tha 
Buraau naada to look at In its BIS. 

Matlanda habitat in California ia In critical 
naed of thla watar. Aa hoaa to alvty parcant of tha 
Pacific Plyway watarfoul population it haa ahrunk froa 
a total of about four million acraa, originally, to a 
fraction or about thr*a hundrad thouaand today. 

California Matarfoul Aaaociation aatliMtaa that 
two-thirda of tha raaaining aarahaa would ba loat If watar 
la not aat aalda for praaarvation. 



26 A 

Ma na«d to a«t aalda fraah watar. It'a particularly 
acuta BOW aa wa ara b«ooalng awara of tha problaaa ot 
uaing irrigation drainaga watar for Matlanda. It's 
beconLlng claarar that thla watar in many caaaa cannot 
aubatituta tor fraab watar. 

Tha BIS atAtaa that tha anvironaantal affact ot 
signing naw watar eoetracta will ba addraaa«d latar on 
in BIf'a oa watar aarkatlng and on Individual contract!. 
Ma faal this ia &n inad«quata procaaa bacauaa tha Bureau 
and tha Dapartaant nood to aaaaaa tha lapacta now at 
tha daclalon polDt that la going to triggar tha aigmn^ 
of thaaa naw contracts. 

Tha wbola body of MKPA law aupporta analysing the 
iBpacta at tha point of dacialon that la tha baginning 
point, bafora a whola aartaa of avanta unfolds. 

That thaaa n«w oontracta will ba aignad are 
claarly llkaly oona«quaacaa of tha action bafora the 
Dapartaant and tha Bureau. Tharafora, thay auat be 
analysed in thla docuMant. 

Purtharaore. thla action itaalf baa a direct 
effect on tbe aaount of water that will be aada available 
to the Bureau to provide to Metlanda becauae the aaount 
of the apiit between tha Central Valley Froject and the 
State Mater rrojact deterainea how auch ia available 
to the Federal Govamaant to provide to Metlanda. 



27 

So, this specific action itself hes a direct 
effect on how auch watar could be swde available to 

Metlands. Therefore, tbe impact on Metlends needs to 
be analysed in the BIS. 

HEPA also raquiras an evaluation of cuaulative 
lapact. By ignoring tha iapact to Metlands of this 
decision, the BIS haa overlooked a vary significant 
cuaulatlve effect ot the decision. 

I'd Ilka to Just co^Mnt, too, it's ay onderatAndlng 
that what the Bureau is planning to do ia to do a series 
of EIS's on water aarkating in varioua aervice areas 
snd Chen EIS's on individual contracts as they dees 
necassary . 

If tba scoping analysis for the Sacraaento 
aarkating prograa is what tha Buraau haa in aind, 
I think it ia isiportant to r aai ber that analyaia- has 
to be dona at soae point. And we believe It needa to 
be dona right here in conjunction with the COA — aarkating 
CVP-wida, not just on s servlce-aras basist not just 
on an individual contract basis. 

Tha SIS does adalt that aoae haraful anvironaantal 
consaquancas will raault froa signing tbe COA, primarily 
due to watar ralaaaaa froa reservoirs during dry years, 
which will raiae downatreaa river tei^keraturaa . 

To cite • conaaquanca of thla, tha SIS indicates 



28 

that increaantel aortallty of Chinook aalaon in the 
Bacrsasnto River would increaaa during dry yeara by 
two to twenty percent at current operation levels and 
by thirteen to seventy percent at tha level of operation 
asauaed ia the year 2000. 

In fact, Piah and Hildlife said In ita draft 
report on the COA, quote. *Tbe extirpation of the 
winter-run aalaon race la not inconceivable under this 
action.' 

Given the serious nature of these potential lepactg. 
we believe that the BIS needs to propose eitigaciori 
aeasurea to help alleviate the impacts. Instead cf 
doing that the draft aisiply points to existing laws arc 
ragulationa and aaya aora atudias ara needed. It doesr ' • 
aake any apeclflc proposals. 

Bxea^lea of tha types of mitigation measures. 
apecificslly, that would be appropriate can be found 
In tha Piah and Mildlifa Service'a dratt repor-. 

Than the third area that wa find the EIR/CIS to 
be Inadequate Is In its treatment of daciaion for 19B^ 
atandards. 

Aa Hias Orlggs pointed out', it ia widely believed 
that thoae preaent atendarda do not provide aufficiant 
protection for the Delta, and the State Board is planning 
to addreaa this by promulgating new atandards in 1987. 



137 



29 

M* conalter thm fallurs of Um COA to m^M* 
provision (or strlctar atAAdards a aajor •hortooalnQ. 
But r«9ardl«aa of whathar tha COft aakaa provialooa (or 
•tricur atAndarda, tha lis auat discuss this llAltstlon 
of t»M COA. 

It auat addraas what wiU bappan to tha CW'a 
Sibliity to aaat nmm atandarda if all tha vatar b«s b*an 
ooncxsctttd away . 

In conclualon. It miac b* racoqalisd thAt ths COJl, 
whila in seas r«ap«cts a stAp forward lor tb« ■■irlrnnwanT , 
also haa aoaa aarlous nvqatlvs lapllcaciona (or tha 
^n--i rnnaar- . 

ftocausa tba CIS doaa not aoaiyia th« iM^ativa 
cons*qu«ncaa of thm COA, w« ballsva tlist It la 
fuAdsaantally luadoqusts. Thank you. 

Mil. nCDANIU.: Thank you. Mo MXt hava Milllaa 
Oavoran . 

Ml. MVOUMi Tnsnk you, Mr. McDsnlsl. flood •v«aiB9, 
G«ntl«aMn. 

I think w laat saw oacb oth«r In this sotting 
ac Stockton, alwut two yaars a9o7 Aad I raaaatoor bl— dlnj 
all over tha floor bocauaa I IsariMd thcra. trom a Stat* 
raprasantaciva, DHS apokasBsn. that thara was to b« no 
EIS. And that waa bacausa thara was no physical Uipact 
of tha COA. Do you ra— bar all that? 



3D 
21 



31 

you will. 1 couldn't find it. If you caa oorract aa oo 
that I hopa you do it and do It soon. 

Tha Stzipod baaa IndaK, until about (iva yaars 
aqo, was hailad loudly avary tiaa 1 opanad ay south 
criticising it, as tha bast young-of-tha-yaar flahary 
indax In tha Unitad Stataa. And I hava acoaptad that. 

But ay quaation la, sows thing auat ba wrong 
bacauaa tha Strlpad Baaa Indax la crashing and, of 
coucsa, tha fishary is ccsahing, too, as wa know It. 

And tha Strlpad Bass Indax rapraaants tha hlgbast 
art (ora wa nsva of (adarsl snd scata biologists working 
With (adaral and stata anginaars to datarklna tha a((acts 
and lapacts o( tha (adaral and atata watar projacts on 
tha Bay-Dalta astoary . 

And you don't know today why tha Strlpad Baaa 
Indax. pradlctad and obsarvad, haa baao out o( whack sinca 
1977. 

Vat, (or yaara you plannad projacta aucb aa tha 
Parlpharal Canal on tha baaia of tha accurscy o( 
pro]acting 110 Btripad Baas Units if wa had tha 
Paripbarsl Canal. 

Ha'va got tha D-14tS/Dalta rian in placa. And 
it la baaad on. without projact calculations, aa you kaow. 
And tha calculus on with that pro)sct Btripad Bass Indai 
la 79. 



I was pratty vocKarous about it. You shouldn't 
hava forgottan so quickly. I waa glad to laarn, about a 
yaar and a halt latar, that you did daclda, golly, it 
doaa raqulra ar. BIB. And t'a glad you'ra hara tonight. 
And !'■ glad tbara's a draft SIR/EIS out. And I'a glad 
that tha pbysicsl aapacts of this pro]act ara baginning 
to ba racognltad. 

To land a Uttls draaa to what you'ra about, I 
cltppad Jia fraaasn's fishing scout raport out o( 
today's Cbronlcla, snd wa'll gat to tha apacitica in 
a Kinuta of tha inadaquacias of tha atstament . 

1 )uat wantad to raad thasa bscausa a yaar or 
two fro« now you sight not ba raading thaae 

*0n tha Baya, planty of baas, (ivs to nina pounds. 

ao«a go to twanty pounds. San Pablo Bay with 

bass thirtaan to twanty-aavan pounds. Suisun Bay. 

atrtpars to thirty pounds. In tha Oalta. 

•trlpars in tha thirtaan-pound claaa ' 

Msll, you Bight hava s hard tisM finding reports 
Ilka that starting next yaar, yaar after that. And I 
think ona of tha reasons you aiqht hava a hard tise doin^^ 
that is tba failure of tha aganclea who write auch reports 
such as this to racognise real tiaat real problena. 

And. (or axaapla, I challanqc you to find the 
word "Btripad Bass lodax" in this report. I don't think 



12 

8o, D-14l$/0alta Plan is praaisad on obtaining 
a Strlpad Baas Index of 79. That is not aaotionad in 
hara. Tha bighast tha Strlpad Bass Index has baen aince 
1977 is 41. It raacbad its lowest level this yaar, €.3 
Ttiat'a not santlonad in hara, 

Mhat you are naglecting is 40 yeara of govarniiwnt 
biology. Tbat'a what you're neglecting. And there'a not 
a word of it in bare. And I really object strongly tc 
that. Aad you can start saking corrections in tenna of 
that failurai I'd racomend that you stsrt rewriting on 
page 49, where you cita 'etripad bass.' 

The next, eost aarlous ihadequacy I think you 
hav* in the raport ia coaparabla to 'aisslng the boar* 
on 40 yaars o( biology by your own people. And that is 
on tba caah value o( theee tiahanaa. You've masec :-. 
thara. too. Kou can find a nuabar on page 49. Vou can 
(ind tha ouabar, aupposad values of striped bass — 
annual value*. 

It is a totally datsd nuabar. Vou can begin to 
gat aoae adequate nuabers In this report cited earlier 
by Lori Crlgga and others— the Heyer Raport. 

It begins to put aodarn valuationa on tha auhject 
you people bava baan daaling with all these yaars as 
repraaentativas of tha agencies. I aa concerned that 
there's no serious aantion of toxics and the project's 



138 



33 
relationahlpa to toxica in tbis •valuation. SoiMday you 
ara 90109 to hav* to accapt aystaBie toxlf icatlon of 
the ayataa by your own pto]*cta. I will do all I can to 
maka you accapt that v«ry aoon. 

I'n thinking, of couraa, of th« (act Uiat 0-14I5 
And Oalta Plan concarn watar (Iowa, watar controla of 
flowa. and Oalta Plan part of it, which 1* alwaya naglactad 
-- you luac hear paopla aay 14«5i that'a watar right* — 
SQRwDody better taJta a cioaar look at tha part bahind 
the alaah which la tha Delta Plan; ahorthand for the 
Wacer Quality Control Plan for tha Sacraaanto, San Joaquin 
Delta and Suiaun Marah. 

That la an official fadaral-atata-approvad plan 
under Section J03c of the Clean Natar Act. So, I would 
recomwand in addition to that one aantance you have in 
Appendix "P," aaying that you do co^ly with Section 
404 of the Clean Hater Act, I auqqeat whether or not 
you do co^ly with Section ]03c of the Act aa that Act 
IS Applied in tha fors of tha Delta Plan. 

Another aiaainq phraaa out of tha paat — I can't 
find in hare -- refara to a project wa all ua«d to ktiom 
a lot about and hear a lot about called tha S«a Lui< 
Drain. t can't find those words in here. And I think 
we nead a aora apt description of tha atatus of that 
drain. And particularly I believe you naad a description 



14 
of what tha federal and atate projecta are qoing to do 
about aituationa resulting in toxification of the 
■yataas which they, thenselvea, produce. And, of course, 
I'b referring specif ically to the aceaa west and north 
of Mandota, served by the Bureau of Raclajnation, which 
froB 103,000 acraa of tila-drainad lands produce flows 
directly and indirectly into the San Joaquin River which 
are chemically equivalent to tha flows which created 
a toxic au«p at Kastarson in two years. 

These flows have bean coainq into the San Joaquin 
River and into the Delta and tha Bay for JO years. Now, 
It haan't been 103,000 acre* for 30 years, but that's 
tha total nuAbar today, we're told. 

I think those are tha kind of thinqs that muat 
be considered. If you sign an aqreenant bare, if you 
have an agraaBent which aakaa everyona happy who's in 
tha water astabiishaent because it aakaa it eaaier to 
take Bore watar out and aova it to payinq cuato«era 
aoaawhare else, you've got to start considering these 
i^MCts that have been naqlactad for 40 and SO years. 
In tha State project's case, only been neglected for 2S. 

I aha re strongly Lori Grlqqs feeling -- I'm aocry -- 

MS. KINCi Laura King. 

MR. DAVOROli LiSura King's feeling on the impacta 
on tha wetlands of tha Central Valley. This is another 



u 

5? 



3S 

unspoken problaa that doesn't gat aantionad. But it's 
another area of aerioua naglect by tha Bureau of 
Reclaaation in that they have never provided watar, 
power, or anything else, in a generous way, to the 
refuges that thay have baan stuck with •■ Biltigatioo 
in tha Central Valley. 

And we're talking here about the diaappaaranca 
of two Billion acres of watlanda after 1930. And 
that disappearance waa caused by highly-subsidixed 
irnqatiOD agriculture delivered through the Bureau of 
Reclamation. 

Now, we have wonderful aitigatioo like the San 
Lula Drain Project itself. But raaambar, in lust 1979 
this was all covered in a report and a dacision by tha 
responsible agencies that this drainage wea going to 
be taken care of with regulating raaervolrs also serving 
as wetland resourcea and Bsrahaa, sis or seven of thaB, 
along the drain. And this would qualify tha project for 
at least SO-percent reLBbursability as a public coat — 
to create aix or seven little Kestersons, we've learned. 

I will give you aoBB of this in writing to aaka 
It easier on you. and I'll cite page nuaibars. And I'b 
qlad you're here. And I'b glad you've don an CIR and IXS. 
And I find it quite inadequate, and I hope you do a better 
]ob in tha final. Any questions? 



6 


11 


« 


11 


I 


14 



36 

HR. HCOAMItLi Thank you. Bill. Next, we have 
David Okita. 

MR. OKITAi Thank you. I'b speaking for the 
Contra Costa Board of Supervisors, who are the governing 
board of tha Contra Costa County Water Agency. 

First of all. we'd Like to thank vou for holding 
tha hearing in Concord, in the heart of the Bay-Delta 
estuary, which is very Bucb affected by this agreeBsnt. 
And we hope you coaa back for future encounters with 
us. 

Toa Torlakson, supervisor froa the district in 
tha Delta, Bade a stateaMnt at your October 22nd hearing 
in Sacraaanto, and X have extra copiea of those. And 
wa would like those entered into the record for this 
hearing. I won't go through thea. 

We have aany of tha saaa concerns that the 
other people raiaad about Decision 14BS, water quality 
standards, the striped baas, and wa will ba outlining 
those in a little bit aora detail in our written statement 
to you before your daadlina. So, I will end with that 
and Juat leave you with a few of these. 

MR. HCOAMICLi Thank you. Ne next have Toa Graff. 

MR. GRATPi Thank you. Pirst, I want to 
congratulate Larry and Dave Schuetter. who lan't here, 
(or the years that thay have put in on thia agraeaent 



139 



to btinq It to th« polot wbara politician* and 
•nvlronaontallBta and othara can taka potahota at it. 

I want to harkan back to our taatiaony in Maahinqton 
l«*t May whan Ma addraaaad tha COA and found Utraa mMjor 



Ona, Ma atatad that tha agcaasMnt waa only (or 
a llBitad duraclon. Tvo, wa atatad chat tha agraaaant 
laft aabiijuoua, Mhac would b« tha Cantral Vallay Pro]act'a 
raaponaa. Mhan naw Oalta atandarda and, hopalully, ftay 
atandarda ara adoptad by tha Stata watar Raaourcaa 
Control Board. 

^d thraa. Ma notad that tha agraaaant includad 
a provlaion (or tha aala and wlalding o( CVF Matar to 
and by tha Stata Natar Ptojact. which MouJd potantlally 
coiHilt a aigniflcant aaount o( additional watar to 
Oalta axport that would otharwiaa bm availabla for 
Dalta outflow raquiraBanta to aaat tha n*ada o( tha 
Dalta, Suiaun Harah, and tha San Pranclaco »ay . 

I want to taka thia oppurtunity to publicly 
thank Congraaaaan Millar (or In larga aaaaura taking 
cara of thoaa thraa principal concarna In UR 3113. 

Ha waan't abla to do all of what tra aakad hia. 
It ia atill poaalbla for tha Padaral GovanuMnt to 
waaaal out of tha COA but only a(tar going through a 
■igniticant aat of gauntlata. 



Thara la no •ora aabigutty xf HB 3113 la paa»ea 
in ita currant for* aa to whathar tha CVP in tha future 
will hava to aaat Dalta atandarda and Bay atandards, 
and tha coiMltaant to tha Nhaaling contract is 
aliainatad, baalcally, by tha nmw lagialation aa there 
la a raqulraaMnt In tha naw lagialation to bring aucr 
a contract, if It ia tndaad negotiated, back to the 
Congraaa for (iirthar Congraaaional action 

And I think it'a quite a raaarkabl* lent, 
really, principally of CongraaaMan Miller and others 
wbo were working on thia, that thaaa iMprovaaanta in cne 
COA ware aada a part of Hfi 3113. 

I alao want to thank Senatora Cranacon and Wilacr. 
whoa, I undaratand, have both endorsed 3113 in its 
current fora without aaandaants and alao Covernoi 
DanhM] 1 in. who I understand haa done the aame in i 
latter to Senator McCluie. 

Me ara concamad, however, at the rmHem 
Govamaant'a continuing raaarvation about HR 3113. 
Particularly, I want to refer to a letter dated 
October 10th, 198$ that Secretary Hodell, actually 
1 guaaa it waa algned by Aaaiatant Secretary Broadaan . 
if !'■ not aiataken, aent up to Sanetor McClure. raiainq 
problaaa about UR 1113. 

Let aa quota froa that letter a few paragraphs. 



a 

24 



39 

"laplaaantatlon of tha Coordinated Operating 
Agraaaent would free a aubatantial block of 
CVP water for which the atatua la currently 
uncertain (or future watar aarvlca contracts. 
There have been nuaeroua requaata for 
additional water froa currant CVP contractora. 
although deliveries of additional auppliaa 
in aoBM casea would ba contingent on the 
conatruction of new conveyance (acllitiea and 
in other caaea the new auppliea could be uaad 
alaost lOHMd lately 

'While we can eupport HR 3113 to the extent 
It authorises and directs tha Secretary to 
execute and laplaaant the Hay IftS COA, we 
have aa)or raservationa and concarna with tha 
raaalndar of the bill.' 
Hell, in effect, what tha Secretary aeeaa to 

want to do la to go back to the Nay draft about tha 

laiprovenenta that tha Houaa, lad by Congraaaaan Hillar, 

put into tha leglalatlon. 

And In particular, let aa quote further what the 

Secretary aeeaa to want to do about the Delta and 

San Pranclaco Bay. The letter goea on; 

*I ehould be reaaabered that the COA does 
not address state watar quality atandarda 



i 


13 


} 


l> 


I 


14 



40 

(or San Pranclaco Bay. They could not bt: 
included ainca no auch atandarda exiat. And 
it rassalna uncertain Mhether auch atandards 
will ba a coaponent of the new Delta atandards.* 
I'a afraid that'a right. I an becoaing a little 
worriad that the Stata Mater Raaourcaa Control Board 
iSD't taking aarioualy ita obligation under paat deciaions 
to laplaaant bay atandarda. But at least tor the 
■oaant that Congraaaaan Millet was right when nc atatea 
on the floor of the Houaa that tnat was an expectation 
of tha Houaa of Rapraaentati ves, that the State wouia 
carry through on ita proaiscs. 
The latter goea on: 

*HB 3113 aakea these previously aeparate 
conaidarationa part of the present CVP 
co^itaent to water quality and aa aucr .- 
becoaaa eaaantially an open-ended . 
nonreiaburaable cowaitwent — "■ 

And 'open-ended, nonreimbursable cosmicrr?"- " 
la underlined. 

It goea i^n. 

'Appropriate cos^roaises related to tnt 

uaa of CVP watar for watar quality purposes 

ara already Included In the COA ' 

The iaplicatlon of that la the seat that th^ 



140 



23 
24 



41 

r«d«ral CovarruMnt wants to do is &-1485. It's b««n 
criticliad by aany oth«r spaAkara tonight. 

'Ma baliava that any changa froa tha COA 
Involving tha uaa of CVP watara for 
aaiinity Kitiqation and watar quality 
•nhancanant auat ba aub}act to tha ganaral 
principla of ralmburaaaant. And in support 
of this position tra support and wa offar 
this draft AMandacnt.' 

Now, lat a« say that tha principla of raiaburacsMn 
in ganaral is on* that BOP supports. And whan tha 
issua originally caaa up in tha discussions on tha bill, 
wa favorad a poaition and officially aant a lattar to 
CongrsasKan Miliar stating that wa opposad tha 
nonralBburaaaant proviaion that indaad appaars now in 
tha final draft of tha bill. 

Howavar, what tha Adaintstration is aaklng for 
is not, if fact, ganaral raiabura«a«nt by Cantral 
Vallay Prolact oontractora of aitigation for thair 
daaagaa cauaad to tha Dalta and Bay. Inataad, what 
thay would do is hava thaa raiabursa only up to tha 
lavel of tha D-148S standarda and than r*quira a aignad 
contract with tha Stata or with soaa othar antity for 
any inprovaaants in Bsy-Dalta watar bayond tha D-1415 
atandarda, which la a prascription for navar having 



4; 

thoaa atandarda ba i«prov*d. Mall, that is totally 
unaccaptabls . 

How. having said that, lat aa rsturn briefly to 
tha IIS. X think Boat of tha othar. or aany of the 
othar apaaksra, hava daalt with tha points that I was 
going to raisa. 

I do think it ia^Msrtant to daal with, what about 
iaprovad Dalta standards ara going to ba required if 
tha Stripad Bass IndsK is avar going to ba brought up 
to sosM kind of raasonabla laval ~ navar aind historical 
iavals •• what about tha iapact of Bay standards, what 
about tha watar that's naadad for watarCoul are«s 
throughout tha vallay? 

As Hiss Ring said, tha BIS claiaa that future 
ElS'a will daal with this isaua. That is not anouah 
Thay hava got to ba daalt with in tha final CIS here 

In addition, if for soaa reason HR )113 is 
aaandad, and tha tarainatlon — and tha Mhaeiing contract 
and tha *no coSMitaant to future standards* provisions 
ara aoaahow reinstated, those hava to addreaaed in detail 
as wall. Thank you. 

MR. NCDANIBL: Thank you. Let's see. Next w« 
hava Hr. Fradarick Bold, Junior. 

MR. BOLDi CantlaaMn of tha Panel, I would like 
to auggaat to you and to racoaswnd to additions to the 



43 

draft BIS/EIR. Let aa preface ay two racoiMandations 
by pointing out aoaathing that's rather obvious 
us In Contra Costa County, tha principal thruat. tha 
aaln force of the Coordinated Operating Agraaaant is 
containad in Section 11, wherein, it is stated that 
the two pro]ectB will ba oparatad in eonformxty with 
quality atandarda aatabliahad by tha Stata Natar 
Hasourcee Control Board. 

Whet then le the environaantal iapact of coaplying 
with thoaa quality standarda? 

Hall, when Decision 14tS was adopted by the State 
Board, thay published this voluainoua Bnvironaantal 
Iapact Report which eete forth in detail the phyeical 
effect on tha environaent that those etandards will have. 
And I think it's reasonable to aaauae that whan tha Stata 
Board re-exaaines the Delta quality standards in 1986, 
they will aleo hava an Bnvironaantal Iapact Report, aa 
indeed we anticipate that tha Bureau will in due course 
publish an Environaantal Iapact Report on tha Drain and 
other aattera. 

I would eugqeat, however, that in addition to 
these physical iapacts of Dalta watar quality atandarda, 
that tha report should atata that tha Coordinated 
Operating Agreeaant does two iaportant thinqa: 

First, it seta at rest this iasue which has 



I- 



44 

troubled aa for 20-odd yaars, whether quality control 
in tha Dalta la an authoriiad purpose of the Central 
Valley Project. And by Congressional action, authorixing 
the execution of the COA, Congress will be stating and 
acknowledging that the operetion of tha Central Valley 
Pro]act In coordination with the State Hater Project 
to aaintain quality atandarda in the Delta is ar 
authorised purpoae of the project. 

Sacondly, I racoHsand that you add in your 
atataaant and EXR tha fact that Conqressional authorization 
of execution of tha COA coaplataly eats aside and 
eluunates any possible contention that aaintaininq 
quality in the Delta is inconsiatent with a Congressional 
directive . 

Indeed, thia will ba a Congreeeional directive. 

But the CVP, in coordination with the swp ihail 
be oparatad to aalntaiD quality standards in the Delta. 

Now, I racoqnite that it could be argued tha* 
thass sre conclusions of law that derive froa Congressional 
eccion authoriting execution of the agreement 

Night I answer such an arquaent by pointing cut 
that your Bnvironaantal Statanent/Environaental Inpact 
Report aeta forth tha accoaplishaent of the eqreenent . 
And I subait to you that these are two very iaportant 
accoapliahaanta of tha agreeaenc that will radouno 



141 



JO 
21 



24 

2S 



4i 

qraatly to th« public lnt*rttat. Thank you. 

MR. NCDANIELi Thank you. Prad. That la the 
Hat that I bava. htm thara othara who would Ilka to 
■aka atatasanta? 

If not. than wa will opan tha Baatin9 tor 
quaatlona. Ata thara quaationa that you alqht hava? 

HR. OKITAi Can you anawar tha quaat ion that 
Lrori Crigqa had about Prlant and Haw Halonaa not 
balnq Includad in tha COA? 

m. NULLHIXi I'll glva It a try. I guaaa !■ 
tha baat th&ng. 

wa. whan wa flrat workad on tha COA, wa lookad 
at tha affact of Dalta tranafaca and aaaantially 
Friant and tha Oalca-Mandota Canal ara rathar tlad 
toqathar in tha Exchanga Agraankant. And wa lookad upon 
that aa a aaparata part of tha CVP fron tha atandpomt 
that tha watar Chat 'a going down tha ayataa at tha 
praaant tisa did not aatlafy Oacialon 1495 atandarda, 
a vary aaali portion of It. 

And that'a ora of tha raaaona for laavlng out 
Fnant. And, frankly, whan wa got to Haw Malonaa. 
that thara vara pro'a and con's at Naw Malonaa. And 
thia haa baan workad on alnca. whlla Naw Malonaa waa 
Btlil in the throwa of 'Could it ba filled?*. Tha Buraa 
waa working with tha Board — or not working with the 



4^ 

ntt. CRATP: Than It bacoaaa available aa part 
of tha general available watar tor aaport? 

HX. MJLLHIli Na ar« not counting It aa part of 
tha watar that'a o*caaaary (ro« tha Buraau'a obligation 
and tro« the Stata'a obligation to aaat Delta water 
outf low. Doca that anawar that? 

Ic haa a vary definite advantage froa a flahariaa 
atandpoint bacauae you do not have aa such north-aouth 
flow in the Delta, aa thia Naw Malonaa la uaad . It's 
not a great aaount of watar. In fact, the Plahary Agtaenant 
requirea that watar to ba put down. In that regard 
It's not that oanaficlal froa tha atandpoint of tha 
State Mater Project divergence or tha Padaral. 

MA. NCOANIEL: Yas7 

MR. OAVORENt I don't to ba too repetitive on 
thia subject, but how could you have affected the 
environaent of the Delta/Bay aatuary, page 42. all tha 
way through conaaquancaa, Delta/Bay aatuary. page 60, 
without referring or any dlacuaalona of 1485 — without 
referring to tha without project conditions that 1465 
and tha Delta Plan are baaed on. and aoaahow or other 
referencing the goal of the Striped Baaa Indea? 

How could you do this? X aaan, it's a great 
editorial gap If you }ust look at adltorial gapa. 

MR. WINKLER] I think Bany of th« concaras that 



Board, aa tha caaa say ba — on how to operate Haw 
Helonca. 

And chat would have put such a big bite ot thtr 
apple. 1 don't think we could have gotten through wiir. 
thm COA as wa have today. That'a why it was not 
includad. 

I think the COA as it axista today la tne 
tirat acap in tha operation of tha facilities and I 
think there ara going to ba othara further on down trie 
line 

And It New ttalonea.. aa presently envisioned by 
tns Bureau, is a local prolact and not an export project. 
thara la not watar rights to go beyond the axiatino servi.. 
area - 

MR. GRATF: That's f»ne-- 

MR. MCDANIELi Would you identify yourself, please 

MR. GRAPF: I'm Ton Graff. yeah, but Larry. 
that'a not, In fact, the way it'a going to ba operatea 
for tha next 20-30 years. What's going to be cht 
practical effect of New Helonaa water coming into the 
syaten? 

MR. MULLHIX: I think the practical effect, 
until tha local watar la uaad, it will aaaiat the South 
Dalta In actually satiafylng Delta water quality. The 
practical affect of it. 



you brought up ara warranted. Certainly, you can see 
froa tha report anvtronaantal study and enrivonment,i : 
coata were dealt with troa tha atandpoint of laplanenting 
tha protactiva standards of tha agraastant. 

Tha aubjact of etrlped baaa waa dealt with as 
well aa any other conaaquancas that was found durina 
the evaluation. 

Tha Striped Baaa Index tor predictive purposes 
la now under atudy. It is certainly a valid thing t< 
coaputa each year. However, aince the '76-77 drought 
Fiah and Caaa and othara have warned ua about uaing 
It for long-term prediction. 

Aa far aa getting into detaila about 148S, it's 
difficult to analyse fully naw water rig ita atandards 
for the entire Delta ayatea when a coaplate Job of thai 
requires waaka of taatiaony throughout tha state, 

wa underacand chara'a aany concerns about D-1495 
and there's aany ongoing atudies to resolve those, to 
define thaa. Ana aa you have aentioned. the boara !■= 
alao planning to adocesa ail ot chose is&uea 

In tha aaantiaa, tha COA waa aiaing at bringing 
op^ratione a atap forward in tarma ot protecting tht 
Delta by getting tha axiacing atandarda in place. 

He can elaborate on ao«M of theae aubjects ir. 
acre detail in tha finalj provide aora thinking on therr 



142 



49 

And aoaa of tiM InfocmBtlon which you hava brought 
up on tha rvcant calculations In tha Strlpad Baaa Indax 
■uraly would ba valuabla inforwatlon for tha final EIR. 
Ita uaa •• a pradlctlva tool, thought, w« will hava to 
coordlnata cloaaly with tha Oapartaant of Flah and Caaa. 

HK. DAVORENt Wall, it'* -- aalda froa pradlctlon, 
It'a awfully good as an indication of what'* gona wrong 
In tha past by following conclusions of cartaln vary 
strong angtnaarlng organisations. 

Can you, for inatanca. tall m» — aaaura Ba — 
that tiiara's a biologist, aitlMr fadaral or stata, on 
tha taaa that wrota thla? 

MK. HINKLXRi Tba list of praparara ara llatad 
In tha raport. And, yas, tbara wara. km a aattar of 
fact California Dapartaant of Flah and Qmmm . Unitad 
Stataa Pish and Mlldlifa fiarvlca, did work cloaaly 
in tha praparation of this. 

And wa agraa tha Strip*d Baaa Indax has Laportanca. 
Also, thara's othar valuas to coneidar and tha Stata 
Board racognlsas that and hava put togathar a coMplatc 
tasB of a atrip«d baaa working group to )ust invaatigata 
this Bub]act. And thay still havan't coAcludad tha axact 
raaaon. but thay hava coaa up with pralininary conclusions 
on factors that affact strip*d baas, sad thoaa ara listad 
hara and wa can slaborata on this in tha futura in tha 



StStMSSt sf 

SUPOtlSM TQM TMtJUaOB. COimM COSTA COUVTT 

oa tht 

ourr EwrnowcirTAi d»«ct sumcirT/Kmrr 

for tha 

coouiMTio ormrton mkocht 

OCTSEI It, 1««4 

Thtt itatMsnt crsRMttk prsllalatry cMBssti sf tks Caatrt Cast* Caaat/ Mttr 

A^tKcy ss tha Ortft E«<r1 rasMHttl lapact SUt4B*«t/Mfsrt »« the CssrdlastaS 
Oparatlons A«r«aa*«t kttwasn th« Castral Vallty N^Jsct tad tM Stats Uatsr 
Project. The Contra Ceita County Mattr AfSKjr It forsmsd by the Iear4 Of 
&wp*r*Uort of Contra Coita Caynty anS thty havt atitherltsd a* t* Mht thll 
lt«t*cnt on thtir behalf. 

Contra Coita County llatsr Afancy tuHorU ths Cssrtflastsd Opsrattoni Ayrs^nt. 
The loard of Supsrvltsrs ksi ajiprs«a»4 ttrosf nssort for Hi 3113 ohtch «o«U 
autherijs ths Bursaw sf laclaaatton to txscvts ths Afrsiaant. Hoaavtr, *o so 
hava toat canctnii ak»«t th« (h-aft EIS/EIR. 

Ha art pltsssd that ths fadsral fsvanssat has Sfrsad U ihars r«t»oas1k<1 tCy *«r 
Msting aattr quality rs^wlraMats ist ky ths SUtt Uatsr istasrcti Caatr«l U»r4. 
Howsvtr, «• nota that tha fsdtral oBllfitlSN It i—w*iat facovlaU bscssts ths 
■ursau of Raclaaitloa lua ssly agraad to a««t thos* ttaadsrda la Otclliss 14tS. 
Msa itandartfi rspladsf OacUloa 14BS ars aiRsctsd wlthlR a f«w yaan. Evtn tfltk 
tMi ItaltatioA. ths Caardlaatsd Opv^tUai AfrMMst ii a itsv la ths rlfht 
41rsct1on. 

Our aslN erItlclH of th* Draft EIS/EIK It ths caacUtlas tMt If tha CsaHiMtad 
Opsratlons Afraasfit i* 0iactfts4. ths Biy/DsUs Estasry «mI4 bs srsUcta4 haasd 
0*1 DscMiQN 14S5 itaadirss. It (■ cUar that Baclilts l«t5 lUMar^t hat sat sa4 

canaot protect ths situary. Alto, Oaclitsn 1««3 Mt rcjsctsd by ths caurti at 
lapr«H''1y pro»l»*tsd. Th1« asttsr It itlll sndtr aspaal by tha courti but, 
nsvsrthslsii. It an indication of ths iMdaguacy sf Dsclttaa 144$. Thli It cisarly 
avtdtnt (n ths aott racsat report on ths lUtt sf tha llrlpsd bast fUhtry. Ths 
Mlt racsnt aaatursMnt of ths ttrtpsd bait population thewt that ths fllhsry hii 

ATTACHMENT "1" 



SO 

final IIB/SXB. 

KB. NCDAIIIC1.I Bill, you ara going to be qivint) 
ua written coaMaata and wa'll ba addrassing chose 
coaaants. X doubt w« will ba ablo to anawar all tne 
qvMStions you stight poaa hara this avcning. 
KB. DAVOBCNi I know you can't 
HB. MULUilli Dava, ara you going to aake a 

m. HCOAHlBLi Yaa, John? 

HB. DBVITOi jla, can you qtva us aone indicsticr 
of whan you will coaa out with the final draft of the 
SIS/EIR7 

HB. MCOAMIBL: Ha hope to have it by Che enj 
of tha yaar, John. Ma indicated aarliar the pubnc 
raviaw period la over, when, the 13th of this aonth 

KR. HIHKLERi Yes. 

HB. NCOANIELi It It will give a couple of aontha 
to wrap It up. 

HB. DCVITOt Thank you. 

HB. MCDAHieLi Wall, if there ara no further 
quastions, that concludaa tha aaating. T^ank you for 
coaing . 



dtcllaad ts a« al1<t1as low. TMi ft ast aecaptsbit and Otcliton 1415 autt be 
■stffflsd ts tssurt tha hMlth sf ths ttrlpsd bstt and other ftth and ■lUlift in 
ths sttuary. Dadstaa 14M alts dsas ast Induds ads^iats itaMtardi for Suliun 
Narth. San Frsacltcs My, and ths South Dslta. T>«ts laaSeguaciti theuld tw 
astad In ths Draft EIS/EIK. It it dasrly vroag to tsy that by Haply aeeting 
Oadltaa 14eS itsadards thtt the Day/DsUa Ettuory vin bs protected. 

Mdltlsaally. tb« Draft EIIAIS should have aers Infsraatlon on tha effect 
•f divarslsas An U ths taa astor prsjsctt oa San Fraaclscs lay. Infoiwation Of* 
ths effect sf rstiini fiswf frva atrfcsltural drainage fna the San Joaquin falle? 
sa ths sstuary should «lss bs Included. 

The Draft EIS/EII Rettl that appreilaately one alllion acre-fcrt sf vater frge 
ths Csntral Valley Project vt)l be Mde available for contract. The Drift EIS/EIR 
should sstlaate the effect t> water ouallty and ftihcrlts if this ustor wai usee 
ts aalntain Oalta Mtsr gsaltty above current Osdtlon UIS tUiMards, rather 
thsn bslfif aada available for aipert out of the OcUi 

Csetra CsaU Ceuaty ulll esrsfully Mtch the prsgresi of ths Coordinated 0«erat1oni 
AgrsMsnt, Includinf the Csafrestlena) legltlatlon current))' untfsrMy. Confi 
CssU Csasty la also psrt sf ths isy/Ostta Coaalttee for Hater feltcy Coatenius 
■fclch It also actively astchlnf the profrsit of the Coordinated Opertttoni 
Afrsaasnt. 

He than* yvu for this appartunlty to coaaant on the Draft Elft/EIS and loot 
forward to the sscsod pabi 1c bMr1a« U bs hold In Concord. 



■Ocl 
M.tarlab.itMt.tlO 



143 



KEPOKTEII't qiffiriCATE 
"OOo — 

STATE or C*LIF0RH1A 1 

) •■. 

COUMTY or SACRAMENTO ) 

I, L. KOa WILLS, cactlfy Ui*t 1 «•• cha Court 
llaportar prasanc at the toratofora raport*d procvadinqa; 
thac I raportad in ahortbAnd writlnq tha tors^oing 
public haacinq and that I, tli*r*«(tar. caus«d my abortharvd 
writing to ba raducad to typawrltlnq. Tfaa p*qaa 
nuakb«rad 1 through &0, inclualva, conatltuta a 
tuU. trua. and corract racord ot aald pro c ^adinga- 

IN HlTMESS wueKZOr, 1 hava aubacrttMd thia 
carciticata at &accaa«nto, CalY^ornia on thia 9th day 

ot Hovaabar 1985. 




pu-s 
ZPorrtRs 

30 Alhaabra toulavard 

ianto. CAliforoia 95ll( 



\y-. L [ 



STATUCRT OF CONfiRESMM fiOfttt WUUI 
OMIMMI. SUBOMIimE OH HATn MO KMO KSOUCCS 

U.S. tOUSf OF KPKSOrTATIVCS 

nM.IC MMIK QM TIC MATT EXV I ROKIITAL IIVAa STATDCVT 

(M TW 

COCMUIIIUTU) OPERATIOM MAUIUT 

CCMCORD. CALIFOniA 

ttVUVU 7. IMS 

The draft — »IibimiiUT lHp«ct sUtMMt MMck It tin liAjact 
of thU hMrtnfl tMluatM • critical uniat fpr tMi coor^lMtad 
oparatlofi of t^ CMtrtI ItoUfy Prajtct Md thi SUta Uit*r hnoiact 
In Ullfoml*. 

Thli 1i OM of thi aoit iBporUAt »rw«U avar dtvalo^ for 
tha ftfUirt of aaur poltcy In tMt SUta , aot aalj for tka telu aad 
tkB l«7 Art*, but for all aroas of Callfomlt. 

T^ti Coordlnttad Qporttlom ttgrmtmnt tnvittt • frtHMork for 
tha aaiiatawnt of Ua »UU and fadaral aaur proiacU, aitd It laawa 
that both pre>actt ar« cOMlttad to tha prvtactlon of Oa)U waUr 
4«M)1ty. 

•y 9utraAt«alA9 Dtlto Mt«r quolltjr. thti a^WMt can iHip to 
and tha aatar aart and rollava tlm lagltlatlva paralyiti iriitck has 
)0A9 cripplad o<a- »UU. Thli will banoftt all Ullfontlam - HortJi 
and Sewth. and tteia In tNt CMtral Vallay. Sowtham California and 
telu M MtU. 

locatsa tAlt ayi — Ht 1> to ktttorlc and to tMOOpUg. tho Cowyot 
hat car«fu1ly rofloMd It* provliloM to attyr* tliat It It flically 
r*tpMtUU, •nvlronatntilljr totfid, and oMntitratlvtly fttttblt. 
n* itoyM af tepTMMUttvn hat olraady ptstod ^ lafltlatton. W 111}, 
la aandtu protactlon of «atar qualltjr In tha Dalta and t« authorln 
tha COA. Mb art hopaful tMt tha SanaU will act on 19 lagltlatlon 



iritJifh Ui MKt fW BbAs. 

1 wilt tb MU tfeot botk Mr SUtd'i SbMtort, AIm CraMtM and 
NU tfllftM. hM* aniorwd »ui«fli of ^ ItfltUtlon In tu pr«ia«)t 
fbr«. In bidUliai. ■ irtdt drraj^ bf dlvwrst and ututlljr antbgDolttlc 
«ntar*tU tmu^Mit bMr lUU. iKl^Ing tha NatropoHUn Wttr 
Wttrlct. lUU Md fbrtbral ooatractbrB. and anTlronMnUl or«Mliatiom . 
•yva Uit « SU) It an hittartc *iwaco traatjr' which thould Dr 
•Mctod vithotft Aelty. 

1 «Dw1d Ilk* to brlofly Mtllna ttm hJot prov1t1on» of H.R. 3U3 
f»r thi hNrlnf Pbcord. I ballava thna provltlons aay bo of attlttana 
l» yov In proparlH tho flMl OMlrwaonUl li^act tutMsnt 

% kill iHthorlm tht SacntAry U o»cuU tha UU. and d1r«cts 
tbt itcnt^y f UM Utarlor ta oporau tho CVP to bbtt tha tundards 
fbr Urn DalU and tha Ur m MtAbllihad by tha SUU Haur iMowrce» 
Cantrvt Board. But % lofltlatlen a)to roqulros changat tn law ana 
lb tha frvpou4 COA vlilch aro ottontlal to asiyrc that Itt Intended 
PWOOM aro aat. 

For «t In thi OalU, whota «aUr qyallty has daUrtoratcd is a 
rbtylt of tbo OAperU of tho tw projocu. tho COA and Us l^tlavntmg 
1a|it1*t1on MAt provldo thit btimnca: our Mtar qiallty w11) not 
k* Midaialnod «1th tha tlfnUf of now waur dallvary contracU, or 
■Itb tha caMtrwctlon of addltleiial wilts of tha Ctf. Tha fallurt of 
tha lay and DalU ar«a to haw thna lotltlaaU daaands r«c09>ttcd bj 
itau and ftdoral mUt plaMort hat lad to rogiona) conflict and 
lUlawtM vhlck tevo Injurod all Ullfomtans. 

IV bin nandatot that tha abllgatlon of tho Fodtral fovonavnt to 
■oat SUU aaur quality tUndartft for tha Oalta aalst Ind a pandtnt 
of tha Coordlnatad Opartttom Ayi—wt lualf . as a taparau aatter 
of 1m. Tha divarslon of wotar away froa tho OclU It not dependent 



144 



I 
I 
I 
I 



on tm COA; tha MUr tivply cantrtcti atll contliua limit a CM. 
So. too, auit baiU profcttow for tha >o ana Dalta caattaaa la 



forca. raoartlaii of tha futar* of Vm CM , m ta tka BalU 
hava tho quality of our uaur aapawdawt m tha aftta af itata ar 
fadaral offlcalali. It auat bo pmarva^ as a aatur af In*. tM tiat 
li iriMt ay Mil <0M. 

Tlia lagltUtlan provtaai m addltloMl ufaguart to 3(0.000 
custoaars of tiM Cootra Coita HaUr Olttrlct, udOM oaly laurca af 
drinking uaur U tda Oalta. % lagltlatlea tiarantaa* la fatfaral 
laa tnat ipaclflc MUr quality itandar«s, at laast ai loal a< ttaa* 
conUlni4 In thi Suu loard't 0-I4C alii la aalaUlaai at tla 
Olltrlct't InUU at Dock Slougk. 

ir* CO* alloal tha Fadsral Co»araaaat to antar lata coatrictt tar 
tna convayanca and purchaia of Cantral Vallay projact aatar. Tliaaa 
contracu constltuu t tignlflcant daparttn frva past practlcaa 
■Mcli ou^t not ba approwaa only Igr atfalalttratan af tM praja cti , 
■Ithout adaquata public ravlaa. Tba Coa^ratt auit ha«a m aaaartaalty 
to aiaalna tba confonlty of thata csatraca witb aaaiatas laid awa 
In fadaral lUtutaa goMniIng tl« utillzatloa, tala. and aavalapaaat 
of fadaral Mtar. For that raason, iv bill raqulrai C a ap ai tloaal 
approval of thaaa cantracta. 

Slallarljr, ay bill pre>l«aa tJiat tka Sacratary My iM taralaata 
tha Fadaral 9o«aii»aat i partlclpatlea In tba OM altbaal fint tuk- 
alttlng to tba Congra n a rapart outlining bit raaaoaa far aalag ta 
for a parlod of 180 dayi dirlng ublch Caafrasi li la taatlaa 
alloa a iltuatlaa atara tba opKlaaat af tba FMaral miiMlat ta ' 
protact tba Dalu rasts lolaly on aa aywaaat afelcb can ha ahragata^ 



at tba akia af tia Sacratary af tM Inurlor. 

Tba OM all! alio* far battar plaMilng and coonllnatlon. but It 
obvloualy cannat prauant ihartagaa that aay occur In tba Moiait of 
proioct aaur a<allakla U aaat esntractual uaBltaanu and tha StaU 
aatar aubllty atandar*. Vbaa Mra ihortfilli do occur In tha futm, 
ay bill Mndatai that tha Sacratary raduca dalwarlaa ta all usart 
la ar*r U flnt aaat SalU aatar quality tundarai. 

Ha flrtt mpoaalblllty for aadvlng tboia raductlons ulll coaa 
froa a^cultMvl cantractan bafora raductlom ar« t^otad on 
auilclpal m*n aha lack avallabia alumatlva saircai of uaur for 
aaaaatlal laaaa baaltb and tafaty naa da . 

Juat aa galley Mat caaa lafara gliding, paopla But cmm bafora 
plaatt. Tlril It tha batll u«aa aklck tha projact has baan oparatad 
In tba paat, alU tba na«aratloa af all partial, and It l> a toiaid 
baali far futura oparatlaaa aa uall. 

I|r lagltlatlaa alsa raqulras that aaur sold undar futiva coatracu 
avt ba racallakia U aaat SUU aatar quality suadaras far tba OalU 
aad lay, tloaM tbay ba i*«radad la tba futura. SurplM aatar alll 
r«Mla a«al1ab)a for tala. lut aaUr idilcb Is naadad u aaat 
lavfaUy aataklltbad lay-DalU aatar quality standards It not ■twplua,' 
bad mat ba aaallakia tlrougk tbls racall BChaalsa u aaat this fiaid- 
aaaaul pur^asi. 

Tba EauiioiMbUI la^act Stjtaaaat raaffirm tba caattHnt ta 
OalU aatar quality aMcb It tba cantral tanat af w laglslatlaa aad 
tba OM ttsalf. 

la fbct, tin EIS lapllcttly caacludat tkat If aa fall u ratify 
Ult bistaric tgraaMat, aatar simllat tbrvu^wit tha Suu, and 



uaur quality bara la tba OalU, Bill aadaiAtadly I 

If ua fall u act, Tha EIS aatat, sallalty la OalU HiiiiiiH 
could laparll nat aniy aur arlaklag aatar swpllaa. bat tba faralaf 
and Industrial actlultlat ahlck (rwrlda tbaaaiaat af )a*a aad Mick 
proMU tba acoAMlc vlullty af tha aatlra lay ArM. md atbar iraag 
of tha SUU as aall. IMar tba lia tatloa- agtlM. ullalty, IWk 
and othar contaalnants uould Jaopardlia tha aatar simply af bundrad s 
of tbouaands af Caatra Costans aad atbara la Uls araa. That "m 
action' option Is an option aa cannot afford. 

* ba«a alraady saan tba avidaaca af abat *ae actloa* will pvaduca. 
Bass and atbar fish pepulatloaa hava baaa daclaatad, aad aa bava m 
issiraaca tkat drinking aaur tivpllaa alll net graa uarsa. Ito caaaat 
1l>a alth that laKarulnty In tbls cOMty aad that la al« tba CM, 
and Ml 3113. ara la-gantly naadad. 

Tha CM alll nat sol<a auary aatar galley prakiM faclag Callforala. 
tha ulanlia crisis at UsUrsoa katanalr, Mich Is tba diract pradact 
of Irrigation practlcat, llluatratat bM sarlout aad laiaisdlcubla fatura. 
challangas alll la. 

Tba triat and caoparatlw aklck baa pradacad tba raiitiiM 
tahlnd H« 3113 and tba CO* alll la assaatlal If aa ara U aaald falllaf 
back InU tba iiaplclon and raglonal dialslaa Mlcb baa laag ckaractar- 
liad aaur pellcy la tbls suu. Tba CM aM Ml 111] «« latsoM far 
ua all la tba rl^t aay u aaU pallcy daclalaM m Mtar Issms: la 
tha apan. alth full public partlclpatlM aM raalw, aM altb a ca»- 
altaant u thosa goals ahlcb sar«a last tta suu as a abala. 

TIa tiM Ms CMa u apua farwar^ u aM tha suaplclM aM 
sUgMtlM aklck bas iMadM saMd MUr pallqr la tMs suu for tM loag. 



Tka CM iM N.g. J113 prauldat tha fraaaaark for accaapllthing 
tkat (lal. I arga tka laraM af lacl^tlM aM tba Suu af Callfonila 
ta pracaM vlU tbalr Kpiaial gracauu «>r tkis c 



145 



Section 4. DRAFT EIR/EIS 




Environmental Impact Statement/Report 
Coordinated Operation Agreement 

Central Valley Project/State Water Project 



Donald Model 

Secretary of Interior 
Department of Interior 



David Houston 

Regional Director 
Mid-Pacific Region 
Bureau of Reclamation 



Gordon K. Van VIeck 

Secretary for Resources 
The Resources Agency 



George Deuknnejian 

Governor 

State of California 



David N. Kennedy 

Director 

Department of Water Resources 



JOINT ENVIRONMENTAL IMPACT STATEMENT 
AND ENVIRONMENTAL IMPACT REPORT 



PROPOSED AGREEMENT BETWEEN THE 

UNITED STATES OF AMERICA 

AND THE 

DEPARTMENT OF WATER RESOURCES OF THE 

STATE OF CALIFORNIA 

FOR COORDINATED OPERATKMJ OF THE 
CENTRAL VALLEY PROJECT 
AND THE 
STATE WA.TER PROJECT 



July 1985 





Donald Hodel 
Secretary of Interior 
Department of Interior 



David Houston 
Regional Director 
Mid-Pacific Region 
Bureau of Reclamation 



Gordon K. Van Vleck 
Secretary for Resources 
The Resources 
Agency 



George Deukme j ian 

Governor 

State of California 



David N. Kennedy 
Director 
Department of 
Water Resources 



JOINT ENVIRONMENTAL IMPACT STATEMENT 
AND ENVIRONMENTAL IMPACT REPORT 

PROPOSED AGREEMENT BETWEEN THE 

UNITED STATES OF AMERICA 

AND THE 

DEPARTMENT OF WATER RESOURCES OF THE 

STATE OF CALIFORNIA 

FOR COORDINATED OPERATION OF THE 
CENTRAL VALLEY PROJECT 
AND THE 
STATE WATER PROJECT 



Responsible Agencies 

U. S. Department of Interior 

Bureau of Reclamation and 

California Department of Water Resources 



Status: DRAFT 
Statement number; 
Filing date: 



Comments must be received by: 



Abstract: The Proposed Action of signing and implementing the draft Coordinated 
Operation Agreement obligates both the Central Valley Project and the 
State Water Project to meet water quality and outflow standards extracted 
from the State Water Resources Control Board Decision 1485 designed for 
protecting the beneficial uses of the Sacramento-San Joaquin Delta water 
supply. Without this Agreement (No Action), the Central Valley Project's 
participation in meeting these standards would not be assured in 
critically dry years. As compared to No Action, the Proposed Action 
would have beneficial environmental impacts in the Delta and could have 
adverse impacts on salmon spawning and rearing in the upper Sacramento 
and Trinity rivers, depending on how the two water projects would be 
operated in No Action. 

For Further Information Contact 



Bob Schroeder Karl Winkler 

Bureau of Reclamation California Department of Water 

2800 Cottage Way, Room W-2137 or Resources 

Sacramento, CA 95825 3251 S Street, Room D-4 

Phone: (916) 978-4923 Sacramento, CA 95816 

Phone: (916) 445-5955 



CONTENTS 

Page 

SUMMARY . 

S-1 

Purpose and Need for Action g_i 

Description of the Proposed Action S_2 

Alternatives 

Alternative 1, The Proposed Action S-3 

Alternative 2, No Action ' * ! ! ' S-3 

Alternative 3, Modified Agreement ....... S-4 

Alternative 4, No Coordination . . s-4 

Environmental Consequences, Proposed Action 

versus No Action, . , ^ , 

s-4 

Delta-Bay Estuary g_^ 

state Water Project Service Areas ........ s-5 

Central Valley Project Service Areas ....'.'.' s-6 

Rivers and Reservoirs . s-6 

Preferred Alternative 

Mitigation Measures 

Cumulative Impacts 

Chapter 1. PURPOSE AND NEED FOR ACTION , 

Central Valley Project, History and Purpose 1 

State Water Project, History and Purpose 2 

Development of Prior Coordinated Operation Agreements ... 2 

Development of the Proposed Coordinated Operation Agreement . 4 

Need for Action 



Page 



Chapter 2. PROJECT DESCRIPTION . 
Articles of the Agreement 



Article 


1, 


Article 


2. 


Article 


3. 


Article 


4, 


Article 


5, 


Article 


6, 


Article 


7, 


Article 


8. 


Article 


9, 


Article 


10, 


Article 


11, 


Article 


12, 


Article 


13, 


Article 


14, 


Article 


15, 


Article 


16, 


Article 


17, 


Article 


18, 


Article 


19, 


Article 


20, 


Article 


21, 


Article 


22, 



Preamble 

Explanatory Recitals 

Definitions 

Term of Agreement 

Facilities 

Coordination of Operations . . . . 

Forecasting 

Water Measurement Responsibilities. 
Reduction in United States and 

State Exports 

Exchanges, Conveyance, and 
Purchase of Water Supply 

Delta Standards 

Monitoring 

Records 

Periodic Review 

Relation to Agreement of May 16, 1960. 

New Facilities 

Project Service Area 

Third Party Rights Unaffected 

Effect of Waiver of Breach . . . . 

Equal Employment Opportunities . 

Contingent Provisions 

Officials Not to Benefit 



Exhibits of the Agreement 



Exhibit A . . . . 

Exhibits B-1 and B-2 

Exhibit C . . . . 

Exhibit D . . . . 

Exhibit E . . . . 



Analysis of Accomplishments of the Agreement 



Delta Water Quality and Outflow Standards 

Annual Water Supplies 

Sharing Formula 

Wheeling Arrangements 



7 

7 

7 
7 
7 
7 
7 
7 
12 
12 

12 

12 
12 
13 
13 
13 
13 
13 
14 
14 
14 
14 
14 
14 

14 

14 
14 
15 
15 
15 

15 

16 
17 
18 
19 



Chapter 3. ALTERNATIVES 

Alternative 1, The Proposed Action 
Alternative 2, No Action, 



21 
21 
21 



Page 

Alternative 3, Modified Agreement 23 

Modifications Within the Present Scope 23 

Modifications That Broaden the Scope 25 

Modifications That Narrow the Scope 27 

Alternative 4, No Coordination 27 

Conceptual Comparison: Proposed Action versus No Action . . 28 

Operation Studies 30 

Proposed Action 30 

No Action, Case A 30 

No Action, Cases A, B, and C; Critical Period Analysis . 30 

Environmental Comparison of Alternatives 34 

Preferred Alternative 37 

Mitigation Measures 37 

Chapter 4. AFFECTED ENVIRONMENT AND ENVIRONMENTAL CONSQUENCES. . . 39 

Regional Setting 39 

Central Valley Basin 39 

The CVP and SWP 40 

Affected Environment, Delta-Bay Estuary 42 

Hydrology and Water Use 42 

Protective Standards 45 

Delta Agriculture 46 

Delta Municipal and Industrial Uses 47 

Fish 49 

Wildlife 51 

Rare and Endangered Species 52 

San Francisco Bay Complex 52 

Environmental Consequences, Delta-Bay Estuary 55 

Delta Agriculture 55 

Municipal and Industrial Use 56 

Fish 57 

Wildlife 59 

Rare, Threatened, and Endangered Species 60 



Page 

Affected Environment, State Water Project Service Areas . . 61 

Agricultural Uses 61 

Urban Uses 62 

Environmental Consequences, State Water Project 

Service Areas 62 

Proposed Action 62 

No Action 62 

Affected Environment, Central Valley Project Service Areas . 64 

Agricultural Uses 64 

Urban Uses 66 

Economic and Social Conditions 68 

Environmental Consequences, Central Valley Project 

Service Areas 68 

Affected Environment, Rivers and Reservoirs 68 

Sacramento River 68 

Trinity River 71 

Feather River 72 

American River 73 

Environmental Consequences, Rivers and Reservoirs .... 73 

Proposed Action 74 

No Action 80 

Existing Central Valley Project Power Capabilities .... 82 

Effect on Central Valley Project Power Capabilities ... 82 

Proposed Action 83 

No Action 83 

Related Actions and Projects 83 

Facilities Named in the Agreement 83 

Other Projects and Actions 84 

Relationship Between Short-Term Uses Of The 

Environment and Long-Term Productivity 93 

Adverse Environmental Effects That Cannot Be Avoided ... 93 

Irreversible or Irretrievable Commitments of Resources. . . 93 



Page 

Urban Quality, Historic and Cultural Resources, and the 

Design of the Built Environment 94 

Possible Conflicts With Governmental Plans 94 

Cumulative and Growth-Inducing Impacts 94 

Wheeling Arrangements 96 

Purchase of CVP Water by the SWP 97 

Removal of the Moratorium on 

New Water Service Contracts 97 

Mitigation Measures for Cumulative Impacts 99 

Safeguards 99 

Contracts 99 

Physical Measures 100 

Studies and Water Management Program 100 

REFERENCES CITED 101 

INDEX 103 



Tables 

Page 

S-1 Relative Advantages and Disadvantages of 

Reasonable Alternatives S-9 

1 Application of the Coordinated Operation Agreement Sharing 
Formulas Over 6 Representative Days of Balanced Water 

Conditions 11 

2 Conceptual Comparison of Critical Year Operations, 

Proposed Action Versus No Action 28 

3 Comparison of Salinities and Flows at Controlling Stations 

in Critical Years, Exhibit A Versus Tracy Standards .... 29 

4 Disposition of Water in 7-Year Critical Period, 

1928 to 1935, Proposed Action Versus No Action 34 

5 Relative Advantages and Disadvantages of Reasonable 
Alternatives 38 

6 Rare, Threatened, and Endangered Animals In or Near the 
Sacraraento-San Joaquin Delta and the Drainage of the 

Sacramento River 53 

7 Rare and Endangered Plants In or Near the Sacramento- 
San Joaquin Delta and the Drainage of the Sacramento River. . 54 

8 Salinity Relationship to Alkali Bulrush 

Seed Production and Germination 60 

9 Central Valley Project Long-Term Obligations 66 

10 Chinook Salmon Spawning Stocks in the 

Sacramento River System 70 

11 Potential Temperature Impacts of the Proposed Action 

in a Critically Dry Year (1933) 75 

12 Estimated Sacramento River Mean Monthly Temperature 
Increase and Corresponding Increase in Mortality of 
Chinook Salmon Eggs and Fry Potentially Resulting 

from the Proposed Action 76 

13 Sacramento River Temperature-Related Salmon 

Losses — 1933 (Critical Year) 77 

14 Annual Drawdown and Recreation Visits at Selected 

CVP Reservoirs With and Without Coordinated Operation 

Agreement 79 

15 Expected Environmental Effects of Possible Future Actions . . 95 



1 

2 

3 
4 
5 
6 
7 
8 
9 
10 
11 
12 
13 
14 
15 
16 



Figures 

Page 
Major Features of the SWP and CVP 

3 

Unstored Flow and Storage Withdrawals Under 
Balanced Water Conditions 

10 

Projected Delta Outflow 

31 

Projected Salts - Sacramento River at Eon.aton 3^ 

Storage Gained in No Action. Case A (Vs. Proposed Action) . . 32 

Projected Flow - Sacramento River at Chico Landing .... 32 

Projected Flow - Feather River at Thermalito 33 

Projected Flow - American River Below Nimbus 33 

San Francisco Bay Complex, 

43 

Sacramento-San Joaquin Delta 

44 

Projected Salts - Old River at Rock Slough 5^ 

SWP Service Areas and Contracting Agencies . 

OJ 

Projected TDS at Clifton Court 

65 

Projected Chlorides at Clifton Court 

65 

The CVP and its Service Areas 

CVP and SWP Facilities Involved in Storage Withdrawals ... 85 



Appendixes 

A Agreement Between the United States of America and the Department of 
Water Resources of the State of California for Coordinated Operation 
of the Central Valley Project and the State Water Project, USBR/DWR 
Draft 

B List of Preparers 

C Consultation and Coordination 

D Biological Assessment of the Impacts of the Coordinated Operation 
Agreement to Federally Listed Threatened or Endangered Species 

E Flood Plain Management and Protection of Wetlands 

F Clean Water Act - Section 404 Compliance 

G Technical Report on Determination of Annual Water Supplies for 
Central Valley Project and State Water Project 

H Environmental Committments 

I Cultural Resources 

J California Department of Water Resources - Response to Questions 
Related to the Coordinated Operation Agreement 

K California Environmental Quality Act Criteria for Significance 



SUMMARY 



The California Department of Water 
Resources and the U. S. Bureau of 
Reclamation propose to enter into a new 
Coordinated Operation Agreement for the 
State Water Project (SWP) and the 
Federal Central Valley Project (CVP). 
Before executing the proposed Agreement, 
the two agencies have prepared this 
joint environmental document to comply 
with State and Federal environmental 
protection laws. 

This report evaluates the environmental 
consequences of the Proposed Action of 
signing and implementing the draft 
Coordinated Operation Agreement of 
May 20, 1985, as compared to the conse- 
quences of No Action; i.e., not signing 
and implementing the proposed Agreement. 
"Modified Agreement" alternatives, 
involving hypothetical agreements or 
agreement terms not included in the 
Proposed Action, are discussed. A "No 
Coordination" alternative is briefly 
discussed also. 



The Bureau of Reclamat 
Department of Water Re 
that the Proposed Acti 
ferred alternative — 
it would provide a rel 
acceptable basis for c 
operations of the Cent 
and the State Water Pr 
protecting the water-r 
in the Sacramento-San 



ion and the 
sources conclude 
on is their pre- 
preferred because 
iable and mutually 
oordinating the 
ral Valley Project 
oject while 
elated environment 
Joaquin Delta. 



The Proposed Action could reduce the 
capability of the Central Valley Project 
operators to control water temperatures 
for salmon spawning and rearing in the 
upper Sacramento and Trinity rivers in 
the driest years. However, similar 
temperature control problems would be 
likely to exist without the Proposed 
Action. 



Purpose and Need for Action 

The SWP and CVP simultaneously use the 
same channels of the Sacramento River 
and the Delta to convey water, and they 
draw upon a common water supply in the 
Delta. The purpose of the proposed 
Agreement is to assure that each project 
obtains its share of water from the 
Delta and bears its share of obligations 
to protect other beneficial uses of 
water in the Delta and the Sacramento 
Valley. Coordinated operation by 
agreed-upon criteria can increase the 
efficiency of both projects. 

Agencies served by the CVP or SWP rely 
on the project that serves them to 
deliver dependable water supplies under 
their contracts with the Bureau or the 
Department. A coordinated operation 
agreement facilitates more accurate 
estimates of how much water each project 
can deliver. 

The first Coordinated Operation 
Agreement preceded construction of the 
State Water Project. It is known by the 
date of its signing. May 16, 1960, and 
it remains today as the basic coordina- 
tion document. This original agreement 
was proposed to be supplemented in 1971 
by an agreement that was drafted, but 
never executed. The 1971 draft agree- 
ment was adopted on a year-by-year 
basis, with modifications, until 1983 
(with the exception of 1976). After 
1978, the major modification was to 
recognize the Decision 1485 water 
quality standards of the State Water 
Resources Control Board. The year 1983 
was so wet that no coordination 
agreement was necessary. In 1984, a 
1982 draft of the currently proposed 
Coordinated Operation Agreement was used 
to coordinate project operations. 



S-1 



Execution of the proposed Coordinated 
Operation Agreement would suspend the 
1960 agreement, and year-to-year agree- 
ments would no longer be used. 



Description of the 
Proposed Action 

The Proposed Action is execution of the 
draft agreement included as Appendix A 
of this report. This section describes 
what the Agreement would accomplish. 

The essence of coordinated operations is 
the sharing formula, not the water 
supply figures in Exhibit B-1. The 
projects are not to be operated to meet 
predetermined yields, but rather to 
first meet the needs in the areas of 
origin, including the Delta water 
quality standards and flow requirements 
contained in Exhibit A. Only then is 
water exported from the Delta. The 
Coordinated Operation Agreement does not 
affect the rights of third parties 
(Article 18). 

The sharing formula provides for CVP/SWP 
proportionate split of 75/25 responsi- 
bility for meeting in-basin use from 
stored water releases and 55/45 for 
capture of excess flow. The formula was 
arrived at by reasoning, trial and 
error, and negotiation. 

The basic points included in the Agree- 
ment are : 

1. Both parties agree to meet a 
specified set of water quality standards 
(Exhibit a) from State Water Resources 
Control Board Decision 1485. Article 11 
also requires that Exhibit A shall be 
amended to include any new Delta 
standards that are not inconsistent with 
Congressional directives. However, if 
the Secretary of the Interior determines 
that new standards are inconsistent with 
Congressional directives, the Secretary 
is to promptly request the Department of 
Justice to bring an action to determine 
the applicability of the new Delta 
standards to the United States. 



This has been the most difficult area of 
the agreement. During the long negotia- 
tions, it was realized that there is no 
other way to deal with possible changes 
in the water quality standards than to 
leave it up to the courts under existing 
law. In 1978, the U. S. Supreme Court 
ruled in California v. U.S. that the 
State Water Resources Control Board may 
impose conditions on the Central Valley 
Project that are not inconsistent with 
Congressional directives respecting the 
project. Therefore, the Agreement is 
neutral on this legal issue. The 
disclaimer paragraph in Article 11(d) is 
designed to assure this neutrality. 

The standards do not presently include 
permanent Suisun Marsh criteria, but the 
Coordinated Operation Agreement does 
contain a methodology (Articles 11 and 
14) for incorporating the Suisun Marsh 
criteria as they become effective under 
the Suisun Marsh contract being nego- 
tiated among the Department, Bureau of 
Reclamation, California Department of 
Fish and Game, and Suisun Resources 
Conservation District. The parties are 
nearing agreement. Congressional auth- 
orization and funding will be necessary 
for Federal participation. The State 
Water Resources Control Board will be 
asked to endorse the Suisun Marsh 
standards in the agreement. 

2. Each project's annual supplies at 
the 1980 level of development have been 
established: 6.9 million acre-feet 
(MAF) for the CVP and 3.6 MAF for the 
SWP (includes 1.0 MAF for Feather River 
service area). Annual supplies at the 
2020 level of development would be 

8.4 MAF for the CVP and 3.1 MAF for the 
SWP (includes 1.0 MAF for Feather River 
service area) . 

3. The Agreement provides for each 
party's use of the other's facilities 
for both short- and long-terra situa- 
tions. In accordance with requirements 
of Decision 1485, it provides for 
conveyance of Central Valley Project 
water through the California Aqueduct to 
San Luis Reservoir to make up for the 



S-2 



curtailment of pumping during the 
striped bass spawning period. 

Section 10(h) calls for a contract to be 
concluded by December 31, 1988, for the 
purchase of interim CVP water by the SWP 
and the conveyance of CVP water to Fed- 
eral contractors through the California 
Aqueduct. The Central Valley Project 
will have priority equal to that of the 
State Water Contractors for use of the 
California Aqueduct for an amount of 
water equal to the amount purchased by 
the State from the CVP. In addition, 
the State is committed to providing 
conveyance service to the CVP for 
additional CVP water so long as such 
conveyance does not diminish deliveries 
or increase costs of water supplies to 
the State Water Project contractors. If 
both parties fail to reach agreement on 
such a purchase and conveyance agree- 
ment, then this Coordinated Operation 
Agreement may be terminated by either 
party (Article 14(b)). 

Finally, the Agreement calls for peri- 
odic review to determine the success of 
each party toward meeting its objectives 
and to make adjustments if necessary to 
enable the party to develop its respec- 
tive water supplies (Article 14). 

The Agreement fairly protects the inter- 
ests of both projects while meeting 
responsibilities to protect the water- 
related environment. 



Alternatives 

Four alternatives were considered: the 
Proposed Action, No Action, Modified 
Agreement, and No Coordination. 



Alternative 1, The Proposed Action 

Under the Proposed Action, the CVP and 
SWP would continue to operate as they 
have in recent years, although using the 



new formula for sharing unstored flow 
that was not used prior to 1984. The 
new sharing formula does not result in 
physically observable changes. The 
Delta water quality (salinity) and 
outflow standards of the Agreement's 
Exhibit A would be binding on both 
projects in all years. 



Alternative 2, No Action 

In the absence of the Proposed Action, 
CVP and SWP operating procedures are 
uncertain. The projects might be 
operated exactly as they would in the 
Proposed Action, but under current 
Bureau policy, CVP compliance with the 
Delta standards established by or 
acceptable to the State is not guaran- 
teed in critical (extremely dry) years. 
If it did not recognize an obligation to 
meet such standards, the Bureau would 
still have to guarantee water quality in 
the Delta sufficient to meet its 
contractual obligation to users of the 
Delta-Mendota Canal. The Delta-Mendota 
Canal contracts contain water quality 
requirements known as the "Tracy stand- 
ards". Meeting only the Tracy standards 
would not provide water quality condi- 
tions in the Delta as good as those 
prescribed by Exhibit A. 

If the Bureau operated only for its 
Tracy standards in critical years, the 
SWP would still have to be operated in 
accordance with the State Water 
Resources Control Board's Delta stand- 
ards. Meeting these standards without 
help from the CVP would strain the capa- 
bilities of the SWP, and the Department 
could approach the Board with a petition 
for relief. Hypothetically, the out- 
comes of such a petition could range 
from no relief to full relaxation of the 
standards, such that the Bureau's Tracy 
standards would control. Hence, three 
cases of the No Action alternative are 
postulated for critical years: 



S-3 



Case A — Both the CVP and the SWP are 
operated to meet only the CVP's Tracy 
standards in the Delta. 



Case B — The CVP is operated to meet 
Tracy standards, while the SWP is 
operated to make the same contribution 
of water for the Delta as it would in 
the Proposed Action. 

Case C — The CVP is operated to meet 
Tracy standards and the SWP is operated 
to fully meet the Exhibit A standards, 
contributing all the extra water 
required, including that which would be 
the CVP share in the Proposed Action, 

For years other than critical water 
supply conditions, it is assumed in all 
cases of the No Action alternative that 
the CVP and the SWP would be operated to 
meet the Exhibit A Delta standards. 



Alternative 3, Modified Agreement 

Three categories of modification were 
considered: modifications within the 
present scope of the Agreement, modifi- 
cations that would broaden the scope, 
and modifications that would narrow the 
scope. Even though these categories can 
generate numerous other modified agree- 
ments, any of the modified agreements 
would have an overall environmental 
benefit and would differ only by degrees 
of benefit. 



° Merging a Delta-Bay Estuary Fish and 
Wildlife Agreement with the proposed 
Coordinated Operation Agreement. 

In the category of modifications that 
would narrow the scope, the following 
modification was considered: 

' Deleting from the Agreement 

Article 10(h), which requires the 
parties to negotiate toward a 
subsequent agreement dealing with 
water purchases and additional 
wheeling arrangements. 



Alternative 4, No Coordination 

This alternative is not necessarily 
independent of the No Action alterna- 
tive, but it represents a No Action 
scenario that is not considered in the 
analysis of the No Action alternative. 

In No Coordination, the Central Valley 
Project and State Water Project would 
not coordinate operations and would not 
necessarily recognize the same Delta 
water quality standards at any time. 
Without coordination, the project oper- 
ators would not know how much water to 
contribute to and withdraw from the com- 
mon pool in the Sacramento-San Joaquin 
Delta without affecting the beneficial 
uses of the Delta water supply or the 
yield of the other project. 



In the category of modifications within 
the present scope, the following modifi- 
cations were considered: 

Changing the sharing formulas. 

Including the post-1984 Suisun Marsh 
standards in Exhibit A. 

In the category of modifications that 
would broaden the scope, the following 
modifications were considered: 

* A U. S. Fish and Wildlife Service 
proposal to include fish protection 
language in the Agreement. 



Environmental Consequences, 
Proposed Action versus No Action 

Environmental consequences were con- 
sidered as the differences between the 
environmental conditions that would be 
expected to exist with the alternatives 
of Proposed Action and No Action. To 
meet the protective criteria of 
Exhibit A could require project 
operational changes. Any change could 
have an effect; however, in all cases 
the overall environmental protection to 
the resources with the standards exceeds 
those of any of the proposed alternative 
actions. 



S-4 



Delta-Bay Estuary 

The Proposed Action would have no 
adverse environmental effects in the 
Delta-Bay estuary, compared to No 
Action, except that peak Delta outflows 
could be slightly lessened in the winter 
or spring of the year or years 
immediately following critical years. 
The lessening would occur only if higher 
carryover storage were maintained in CVP 
reservoirs with No Action, and any 
lessening that occurred would be too 
small to make a noticeable environmental 
difference in the estuary. 

No Action, Case A, would have the fol- 
lowing adverse effects in the Delta-Bay 
estuary, as compared to the Proposed 
Action: 

High salinity in irrigation water 
taken from channels of the western 
Delta could adversely affect crops 
during critical years. 

During critical years, the concentra- 
tion of total dissolved solids at the 
intake of the Contra Costa Canal would 
occasionally exceed the maximum recom- 
mended by the Environmental Protection 
Agency for drinking water. The EPA's 
recommended maximum concentration of 
chloride in drinking water would also 
be exceeded occasionally during criti- 
cal years. 

The potential for formation of trihal- 
omethanes (suspected carcinogens), in 
the Contra Costa Canal drinking water 
supply would increase during critical 
years . 

° Industrial plants in eastern Contra 
Costa County that make paper and 
cardboard would incur higher costs and 
experience capacity limitations due to 
excessive salinity of their Contra 
Costa Canal water supply during 
critical years. 

° Salinity in the lower San Joaquin 

River during the striped bass spawning 
season of critical years would exceed 



the levels at which striped bass 
prefer to spawn. 

Delta outflow in July, August, and 
September of critical years would be 
insufficient to maintain the entrap- 
ment zone in the Suisun Bay area. 
Resulting decreases in Neomysis and 
young striped bass abundance would be 
expected , 

Detrimental reverse flows in the lower 
San Joaquin River would ircrease 
during critical years. This would 
increase the number of juvenile salmon 
drawn to the export pumps from the 
Sacramento River, 

April, May, and June flows in the 
Sacramento River would be lower during 
critical years, reducing the survival 
rate for juvenile salmon migrating 
down the river , 

Alkali bulrush seed production in 
Suisun Marsh would decline during 
critical years, reducing the waterfowl 
holding capacity of the marsh. 

Effects in the Delta-Bay estuary of No 
Action, Case B, would be intermediate 
between those of No Action, Case A, and 
those of the Proposed Action. Effects 
of No Action, Case C, would be similar 
to those of the Proposed Action. 



State Water Project 

Service Areas • 

The Proposed Action would have no 
adverse effects on the State Water 
Project service areas. 

Effects of the No Action alternative, as 
compared to the Proposed Action, vary 
according to the case being considered. 
In No Action, Case A, the State Water 
Project service areas would experience a 
reduction in the quality of their SWP 
water supply. The reduction would not 
be significant enough to affect use of 
the water. In Case B, there would be a 
similar, but lesser, reduction in 



S-5 



quality. In Case C, there would be a 
reduction in State Water Project deliv- 
eries: firm yield of the project would 
be reduced by up to 143,000 acre-feet. 



Central Valley Project 
Service Areas 

The Proposed Action would commit a 
portion of the Central Valley Project's 
water supply to meeting Delta water 
quality and outflow standards equivalent 
to Decision 1485 in critical years, as 
well as all other years. Operation 
studies indicate that the amount of 
water supply so committed, above that 
required to meet the Decision 1485 
standards in non-critical years and the 
Tracy standards in critical years, 
would be equal to 717,000 acre-feet over 
the 7-year critical period 1928 to 1934, 
or about 100,000 acre-feet annually. 
The same water conceivably could be 
committed to some other use, such as 
supplying Central Valley Project service 
areas. Thus, an effect of the Proposed 
Action is to deny Central Valley Project 
service areas, existing and potential, 
use of the amount of CVP water supply 
committed under the Agreement to meeting 
the Delta water quality and outflow 
standards of Exhibit A during critical 
years . 

Adverse effects of the No Action alter- 
native on CVP customers, as compared to 
what they would experience under the 
Proposed Action, would consist of reduc- 
tions in the quality of water pumped 
into Contra Costa Canal (discussed 
earlier under "Delta-Bay Estuary") and 
reductions in the quality of water 
pumped into the Delta-Mendota Canal by 
the Tracy Pumping Plant during critical 
years. The reduction in quality of the 
Delta-Mendota Canal water would be 
greatest in Case A, but water quality 
would still be within the range allowed 
by the contracts and not enough differ- 
ent, as compared to quality with the 
Proposed Action, to require a change in 
use. 



Rivers and Reservoirs 

Because the Proposed Action would com- 
mit a greater amount of CVP water to 
Delta use and outflow than the CVP might 
otherwise release for this purpose in 
critical years, critical-year water 
levels in CVP reservoirs under the 
Proposed Action could be lower than they 
might be under the No Action alterna- 
tive. Critical years occur less than 
10 percent of the time, and operations 
during other year types would not signi- 
ficantly affect storage changes. Lower 
reservoir levels at Shasta, Clair Engle, 
and Folsom lakes could occur according 
to the operating assumptions used in 
this report and might adversely affect 
esthetics and recreation at those lakes. 
Water temperatures could be increased by 
as much as 4 degrees Fahrenheit in the 
Sacramento and Trinity rivers at certain 
times during critical years. Other 
operating alternatives would have less 
effect. Temperature effects of 
increased drawdown were identified in 
only 3 of 83 years studied, which repre- 
sents less than a 4 percent probability 
of occurrence. Since temperature would 
in any case be marginal during these 
times for survival of salmon eggs and 
alevins (fry with yolk sac still 
attached), a small increase in tempera- 
ture could have negative effects. Tem- 
perature changes in the American River 
attributable to lower reservoir storage 
levels would be less pronounced than in 
the Sacramento and Trinity rivers. 

It should be recognized, however, that 
salmon impacts discussed above are local 
effects and may not occur under operat- 
ing assumptions different from those 
used in the alternatives, yet are still 
possible in the future. Inherent in 
this Agreement is the commitment by both 
the CVP and SWP to meet an adopted set 
of standards designed to protect salmon 
(and other resources) and that meeting 
these standards is judged more benefi- 
cial to salmon overall than if these 
standards are not met. 



S-6 



The temperature impacts of the Proposed 
Action arise only by comparison to the 
No Action cases, and then only if it is 
assumed in the No Action cases that the 
CVP retains in storage the increment of 
project water it could save by meeting 
the Tracy standards in critical years 
rather than the Exhibit A standards. 

Retention in the reservoirs represents 
only one possibility. Another possibil- 
ity is that the water would be delivered 
to CVP contractors. If the water were 
delivered to contractors rather than 
retained in the reservoirs, the environ- 
mental consequences of No Action would 
become more like those of the Proposed 
Action as far as rivers and reservoirs 
are concerned. 



Preferred Alternative 

Relative advantages and disadvantages of 
the alternatives are compared in 
Table S-1. 



Mitigation Measures 

Diminution of the CVP's potential capa- 
bility to control water temperatures 
for salmon spawning in the rivers below 
its major reservoirs during critical 
years could be an adverse environmental 
effect, but this could be mitigated by 
the overall protective standards for 
salmon in Exhibit A. These standards 
are designed to mitigate for impacts to 
the salmon (and other) resources, and 
meeting these standards is judged more 
beneficial to this resource than not 
meeting these standards. 

Temperature control for fish protection 
in the Sacramento and Trinity rivers is 
a recognized concern in the operation of 
the CVP and is the subject of ongoing 
studies. The concern exists with or 
without the Proposed Action, and the 
Proposed Action would not necessarily 
make it any worse. Further studies and 
actions will provide added mitigation. 



The Proposed Action is the alternative 
preferred by the Bureau of Reclamation 
and the Department of Water Resources. 
This alternative is preferred because it 
would fulfill the need for a Coordinated 
Operation Agreement, described above 
under "Purpose and Need", and because it 
would provide greater protection to the 
water-related environment in the 
Sacramento-San Joaquin Delta than would 
the alternative of No Action. Such 
protection would come at the expense of 
diminishing the Central Valley Project's 
potential capability (not necessarily 
its actual capability) to control river 
temperatures for salmon spawning below 
its major reservoirs during critical 
years. 

None of the Modified Agreement alter- 
natives was found acceptable to the 
reasoning and trial and error process of 
negotiations. The No Coordination 
alternative is not preferred because it 
could have serious adverse effects on 
both projects and the environment. 



Cumulative Impacts 

The proposed Agreement could be consid- 
ered a link in a chain of events that 
could lead to other actions that could 
have significant environmental impacts. 
However, future actions beyond this 
Agreement would be necessary and would 
require environmental documentation and 
mitigation. 

Article 10(h) of the proposed Agreement 
requires the parties to negotiate a 
subsequent agreement that would expand 
the wheeling services the SWP provides 
to the CVP and commit the Bureau of 
Reclamation to sell CVP water to the 
SWP. An effect of a \^eeling and water 
purchase agreement would be to increase 
the amount of water the two projects 
export from the Sacramento-San Joaquin 
Delta. 

A moratorium on new CVP water service 
contracts has been in effect since 1979. 
The moratorium was imposed administra- 



S-7 



tively by the Secretary of the Interior. 
The terms of the moratorium provide that 
it will be lifted when the responsibil- 
ities of the CVP toward water quality 
protection in the Delta have been clari- 
fied and the Bureau has committed itself 
to meet those responsibilities. 

After the proposed Agreement is 
executed, the Bureau intends to ask the 
Secretary of the Interior to lift the 
moratorium, thus allowing the Bureau to 
enter into negotiations for possible 
contracts for development of the uncom- 
mitted water supply of the CVP. This 
uncommitted supply is estimated at about 
one million acre-feet annually. Poten- 
tial customers for the million acre-feet 
include the SWP and irrigators in the 
Sacramento and San Joaquin valleys. 

Prior to execution of any long-term CVP 
water service contracts or v^eeling 
agreements with the State, appropriate 
environmental analysis and documentation 



will be conducted pursuant to NEPA and 
CEQA, including an analysis of cumula- 
tive effects. 

Mitigation for cumulative impacts such 
as may be associated with the Proposed 
Action is woven into the fabric of laws 
that protect the environment, such as 
California Environmental Quality Act and 
National Environmental Policy Act, and 
is carried out through actions of 
government agencies, particularly those 
having regulatory powers. Mitigation 
can also be provided through contracts 
and physical measures. Studies to 
mitigate for future project cumulative 
effects are also being conducted, 
including several million dollars 
allocated to monitoring and ecological 
studies. Appropriate mitigation for 
impacts of the continuing development of 
the CVP and SWP will be devised when 
specific projects are proposed and their 
impacts identified in other environ- 
mental documentation. 



S-8 



TAle S-1 
RELATIVE ADVANTAGES AND DISADVANTAGES OF REASONABLE ALTERNATIVES 



Alternatives 



Propwaed Action 
(Compared to Ho Action) 



Advantaqea 



Better overall protection for 
migratory fiah in the Delta during 
critically dry years. 

Higher potential agricultural produc- 
tivity in the western Delta during 
critically dry years. 

Higher productivity of waterfowl food 
in Suistjn Marsh during critically dry 
years. 

Higher water quality for M&I use in 
the Delta during critically dry 
years. 



Dlaadvantaqea* 



Potential for increased drawdoMi at 
CVP reservoirs during critically dry 
years, with minor adverse effects on 
esthetics and recreation. 

Potential local adverse effects on 
salmon spawning and rearing due to 
high river temperatures during late 
summer and fall months of critically 
dry years. 

ftitential for slightly reduced Delta 
outflow peaks in the year or years 
immediately following critically dry 
years . 



No Action, Case A ** 
(Compared to Proposed Action) 



Retains existing CVP option to reserve 
portion of water stored in reservoirs 
for maintaining river temperatures 
suitable for salmon spawning in late 
summer and fall of critically dry 
years. 

Disadvantages of Proposed Action 
avoided if water saved by meeting less 
demanding Delta standards is retained 
in storage. 



Advantages of Proposed Action 
foregone. 



No Action, Case B ♦» 
(Compared to Proposed Action) 



Same as Case A 



Advantages of Proposed Action fore- 
gone, but to a lesser degree than in 
Case A, 



No Action, Case C *» 
(Compared to Proposed Action) 



Same as Proposed Action 



Firm water supply yield of 9WP 
reduced by 143,000 acre- feet. 



Modified Agreement 

(Compared to Proposed Action) 



Potential for increased flexibility. 



Modifications were not found to be 
acceptable to the reasoning and 
trial and error negotiations. 



No Coordination 

(Compared to Proposed Action) 



None 



Decrease in environmental protection 
and in reliability of project yields. 



♦ Nj impacts were judged to be significait based on CEQA criteria listed in Appendix K. 
»*Case A = CVP and SWP meet Tracy stafidards. 

Case 8 = CVP meets Tracy standards; SWP releases its share of Exhibit A. 

Case C = CVP meets Tracy standards; SWP meets Exhibit A in full. 



S-9 



SI 

a 
I 
I 

! 

I 
I 
I 
I 
I 
I 
I 

i 

I 

i 

e 

e 



Chapter 1. PURPOSE AND NEED FOR ACTION 



A Coordinated Operation Agreement is a 
requirement for orderly and efficient 
functioning of California's two largest 
water resources development projects: 
the Federal Central Valley Project and 
the California State Water Project. The 
two projects are operated as separate 
entities by the U. S. Bureau of Reclama- 
tion and the California Department of 
Water Resources, but their operations 
are interrelated, their waters are 
mingled, and their effects on the 
environment occur jointly in many 
instances . 

The purpose of the proposed Agreement is 
to assure that each project obtains its 
share of water from the Delta and bears 
its share of obligations to protect 
other beneficial uses of water in the 
Delta and the Sacramento Valley. 
Coordinated operation by agreed-upon 
criteria can increase the efficiency of 
both projects. 



Central Valley Project, 
History and Purpose 

During the 1920s, a period of rapid 
growth in California, the State's 
political leaders recognized a need for 
large-scale water resources development 
to meet growing needs for flood protec- 
tion and water supply. The Legislature 
in 1921 authorized a statewide water 
resources investigation, which 10 years 
later produced the State Water Plan. 
The plan contemplated transfer of 
surplus water between the northern and 
southern portions of the Central Valley 
in a State Central Valley Project. This 



project, the initial feature of the 
State Water Plan, was approved, first by 
the Legislature and then by the voters 
of California. But the nation was in 
the depths of the Great Depression, and 
the bonds needed to finance the project 
could not be sold. Arrangements were 
subsequently made for Federal authoriza- 
tion and financing. 

Federal legislation authorizing the 
Central Valley Project in 1937 declared 
that its facilities "shall be used first 
for river regulation, navigation and 
flood control; second for irrigation and 
domestic uses; and third for power." 
Salinity control in the Delta was not 
specifically listed as a project 
purpose. The salinity control 
responsibility of the Central Valley 
Project, if any, has been a subject of 
long-standing controversy.* 

Major facilities of the Central Valley 
Project are shown in Figure 1. These 
facilities primarily serve to regulate, 
store, or divert flows of the Trinity, 
Sacramento, American, Stanislaus, and 
San Joaquin rivers, all of which are 
tributary (by way of a diversion tunnel, 
in the case of the Trinity) to the 
Sacramento-San Joaquin Delta. The 
Central Valley Project pumps water from 
the Delta and exports it to the San 
Joaquin Valley via the Delta-Mendota and 
San Luis canals and to Contra Costa 
County via the Contra Costa Canal. The 
CVP also diverts and delivers water 
upstream from the Delta with facilities 
that include the Tehama-Colusa, Corning, 
Folsom South, Madera, and Friant-Kern 
canals . 



*This controversy is chronicled by W. Turrentine Jackson and Alan M. Patterson in 
The Sacramento-San Joaquin Delta, the Evolution and Implementation of Water Policy , 
Department of History, University of California, Davis; Water Resources Center 
Contribution No. 163, June 1977. 



The first unit of the Central Valley 
Project, the Contra Costa Canal, became 
operational in 1940, and many key 
facilities, such as Shasta Dam and the 
Delta-Mendota Canal, were operational by 
the early 19508. 



State Water Project, 
History and Purpose 

Leaders of the California Government did 
not necessarily intend that the Central 
Valley Project remain Federal. At least 
some of them intended and believed that 
it would eventually become a State 
project, as was contemplated in the 
State Water Plan. As time passed, it 
became clear that institutional 
obstacles would complicate, and perhaps 
preclude, transfer of the Central Valley 
Project from Federal to State 
control /I/*. Meanwhile, the growth of 
California accelerated, particularly 
after World War II, and State officials 
perceived a need for a water resources 
developmeat system of far greater extent 
than was encompassed by the Federal 
Central Valley Project. 

By 1951, State water planners were out- 
lining the fundamental elements of what 
would become the State Water Project. 
Some important milestones in development 
of the State Water Project were approval 
of the California Water Resources Devel- 
opment Bond Act in 1960, the beginning 
of construction of Oroville Dam in 1962, 
and the initial operation of the 
California Aqueduct in 1968. 

The State Water Project has contracts, 
most of them made in the early 1960s, 
calling for eventual delivery of 
4.2 million acre-feet of firm annual 
yield. These contracts are with 27 pub- 
lic agencies in the San Joaquin Valley, 
the San Francisco Bay area, and Southern 
California. The project also has three 
contracts with public agencies in the 



upper Feather River area totaling 39,800 
acre- feet as a maximum entitlement. 

Before serving these water contractors, 
the State Water Project must meet the 
prior rights of water users from the 
Feather River below Oroville Dam. 
Agreements between the State and most of 
the users have been signed. These 
agreements specify the value of approp- 
riative water rights in acre- feet per 
year and the acreage covered by riparian 
water rights. Annual draft on Feather 
River flow identified in these agree- 
ments is about 1 million acre-feet. 

Besides these contractual obligations 
and agreements for water supply, the 
State Water Project is required by law 
to provide salinity control in the 
Delta. Recreation and fish and wildlife 
enhancement are also among the project's 
authorized purposes. 

The major facilities of the State Water 
Project are shown in Figure 1. Con- 
structed mainly in the 1960s and early 
1970s, they serve to regulate, store, 
and divert flows of the Feather River, a 
major tributary to the Sacramento River, 
and to export water from the Delta. The 
SWP delivers water pumped from the Delta 
to the southern San Joaquin Valley and 
Southern California via the California 
Aqueduct and to parts of the San 
Francisco Bay area via the South Bay 
Aqueduct. The estimated yield obtain- 
able with existing SWP facilities v^en 
the contracts fully mature is about half 
of the amount the contracts require. 



Development of Prior 
Coordinated Operation Agreements 

Even before the State Water Project 
began operating, State and Federal 
officials realized that understandings 
would be needed to coordinate its 



* See numbered references at the end of the report, 



TRINITY RIVER 



I Figure 1: MAJOR FEATURES 
I OF THE SWP AND CVP 



WHISKEYTOWN RES^ 1 /TEHAMA-COLUSA CANAL 

CORNING CANAL — M / I 

\y ^LAKE OROVILLE 



SACRAMENTO RIVER 




CONTRA COSTA CANAL 
SOUTH BAY AQUEDUCT 

SAN LUIS RES. 



DELTA-MENDOTA CANAL 



l^^ ^^-^FOLSOM LAKE 

-FOLSOM SOU"Yh_CANAL 
\^^ Socromento-Son^Jooquin Delta 
NEW MELONES RES. 

SAN JOAQUIN RIVER 

y-MADERA CANAL \^ 
^-''—MILLERTON LAKE '*v 

SAN LUIS CANAL 

^'•^ 1^ FRIANT-KERN CANAL 

\ 

CALIFORNIA AQUEDUCT 









\ 



LEGEND 

STATE WATER PROJECT 
CENTRAL VALLEY PROJECT 
JOINT USE FACILITIES 



SILVERWOOD LAKE 



LAKE PERRIS 



I 

j 

I 
\ 



operations with those of the Central 
Valley Project. Accordingly, an agree- 
ment was signed on May 16, 1960, to: 

Provide a method of allocating short- 
ages in water supplies by prorating 
the shortage on the basis of specified 
annual diversion amounts. 

Resolve the protests of each party to 
the applications of the other for 
water rights consistent with these 
annual diversion amounts. 

Although the 1960 agreement provides for 
coordinated operations, Article 16 
specifically recognized that additional 
criteria would be needed to actually 
operate the two projects on a coordi- 
nated basis. Negotiations on the oper- 
ating criteria culminated in the draft 
Coordinated Operation Agreement of 
May 13, 1971. That draft agreement pro- 
vided a procedure whereby the operators 
of the Central Valley Project and State 
Water Project would determine how much 
water each project must supply from its 
own sources for uses in the Sacramento 
Valley, including the Delta, and how 
much water each project is entitled to 
export from the Delta. 

Taking the agreed-upon obligations and 
entitlements of the draft agreement into 
account, mathematical simulations of 
project operations were used to calcu- 
late the annual water supply of each 
project. Annual water supply is the 
amount of water that can be delivered in 
all years except during critically dry 
periods, when deficiencies are allowed 
so long as they are within the defici- 
ency provisions of the water supply 
contracts. The simulations done for the 
1971 draft agreement assumed completion 
and operation of Auburn Reservoir and 
construction of a Delta water transfer 
facility such as the Peripheral Canal. 
The calculated annual water supplies 
from the simulations were 9.25 million 
acre-feet for the Central Valley Project 
and 3.78 million acre-feet for the State 
Water Project. 



The 1971 draft agreement was never 
executed, because the Environmental 
Defense Fund filed a lawsuit that 
resulted in an agreement by the Bureau 
not to execute the 1971 draft until an 
environmental document was prepared in 
accordance with the National Environmen- 
tal Policy Act 111 . 

From 1971 through 1982, the Bureau of 
Reclamation and Department of Water 
Resources operated the CVP and SWP in a 
coordinated manner through annual 
letters of understanding in v*iich they 
agreed to operate according to the terms 
of the 1971 draft agreement, with 
modifications. An exception occurred in 
1976, a drought year, vAien there was no 
letter of understanding and the CVP did 
not release vAiat the Department 
considered the CVP's fair share of Delta 
salinity control and outflow require- 
ments . 

From 1979 through 1982, the annual 
letter included an agreement by the 
Bureau to operate the CVP in compliance 
with the Decision 1485 (August 1978) 
water quality and outflow standards 
of the State Water Resources Control 
Board, In 1983, so much water was 
available in the Delta that no coordina- 
tion agreement was necessary. In 1984, 
the project operators informally agreed 
to operate in accordance with the 
sharing formula of the draft Agreement 
that is the subject of this report. 



Development of the Proposed 
Coordinated Operation Agreement 

By 1979, a need to renegotiate the 1971 
draft agreement had become apparent. 
The changed circumstances that necessi- 
tated renegotiation were related to data 
gathered during the 1976-77 drought, the 
State Water Resources Control Board's 
Decision 1485, the Secretary of the 
Interior's decision to voluntarily meet 
certain Delta water quality standards 
stated in Decision 1485, and the fact 
that not all of the facilities described 



in the 1971 draft agreement had been 
constructed. 

In 1979, the Bureau and the Department 
formed negotiating teams to reevaluate 
operating criteria, determine the water 
supplies available for each project, and 
develop a new operation agreement. New 
simulations were performed and refined, 
eventually becoming the basis for 
Exhibits B-1 and B-2 of the proposed 
Agreement and for the sharing formula, 
which derives from Exhibit B-1. In 
December 1982, after about 25 public 
negotiating sessions, the negotiating 
teams completed a draft agreement and 
forwarded it to the Director of Water 
Resources and the Regional Director of 
the Bureau of Reclamation for approval. 
That draft agreement was never approved. 
Negotiations were reopened in July 1984 
at the request of the Bureau of 
Reclamation. Eight additional public 
negotiation sessions were held, 
resulting in concurrence on the draft 
agreement that is the subject of this 
report on May 20, 1985. 



Need for Action 

The Central Valley Project, State Water 
Project, and other projects of the 
Federal, State, and local governments 
and private agencies store and divert 
water in, and export water from, the 
Sacramento Valley basin. They do so 
under conditions established in various 
laws, court orders, administrative 



policies, and other guiding instruments. 
Each agency properly regards the water 
it has developed as valuable property to 
be retained and controlled. 

Unless kept separate, the water of one 
project is physically indistinguishable 
from that of another . Since the Central 
Valley Project and State Water Project 
use the same stream channels simultan- 
eously to convey water, a coordination 
agreement is needed to assure that each 
project retains its share of the com- 
mingled water and bears its share of 
joint obligations to protect beneficial 
uses, including those of the water- 
related environment. Coordination also 
facilitates more efficient use of the 
available water resources. 

The 1960 coordination agreement is 
insufficient as a guide to operations, 
and the 1971 draft supplemental agree- 
ment is obsolete. The latter assumes 
the existence of facilities that have 
not been constructed, outdated demands 
on both the Central Valley Project and 
the State Water Project, and old (prior 
to Decision 1485) Delta water quality 
objectives. 

The proposed Agreement would fill the 
need for a permanent agreement based on 
current project facilities, expected 
demands, recent Delta water quality 
standards, and a new sharing formula. 
Further, the Agreement needs provisions 
to be adaptable to new and changing 
conditions. 



Chapter 2. PROJECT DESCRIPTION 



The U. S. Bureau of Reclamation and the 
California Department of Water Resources 
propose to execute an agreement entitled 
"Agreement Between the United States of 
America and the Department of Water 
Resources of the State of California for 
Coordinated Operation of the Central 
Valley Project and the State Water 
Project". Appendix A is a copy of this 
agreement . 



Articles of the Agreement 

Appendix A contains the full text of the 
Agreement, much of which requires little 
or no explanation. Perhaps the most 
essential terms of the Agreement are 
those concerning operations, particu- 
larly Articles 6 and 10. This section 
reviews the articles. 



Article 1, Preamble 

Names the parties to the Agreement, the 
U. S. Bureau of Reclamation and the 
Department of Water Resources, and 
leaves blank a citation of an act of 
Congress that is proposed to be enacted 
authorizing the Bureau of Reclamation to 
sign the Agreement. 



storage withdrawal" and "State storage 
withdrawal". These definitions are com- 
plicated, but their underlying principle 
is simple: a storage withdrawal occurs 
when water is being drawn out of a 
reservoir or system of reservoirs at a 
higher rate than it is flowing in. An 
exception to this principle is made for 
water flowing into Whiskeytown Lake (a 
CVP reservoir) through Judge Francis 
Carr Powerplant. This water is imported 
to the Sacramento Valley basin from the 
Trinity River via the Clear Creek 
Tunnel, and it is not counted as inflow 
to Whiskeytown Lake. In effect, all the 
Trinity River water is counted as 
storage withdrawal. 



Article 4, Term of Agreement 

Provides that the Agreement remain in 
force and effect until: (1) terminated 
by mutual agreement; (2) the parties 
cannot reach agreement on, and an 
advisory board does not unanimously 
recommend, all terms and conditions of a 
wheeling purchase agreement; (3) either 
party fails to obtain certain water 
right permits or amendments; or (4) the 
parties cannot agree on, and an advisory 
board does not unanimously recommend, 
changes to this Agreement . 



Article 2, Explanatory Recitals 

Gives background information and estab- 
lishes the positions of the parties as 
they enter the Agreement. 



Article 3, Definitions 

Defines terras used in Article 6, Coordi- 
nation of Operations. Definitions 
(b), "balanced water conditions," and 
(c), "excess water conditions," are 
discussed under Article 6. Definitions 
(d) and (e) are for "United States 



Article 5, Facilities 

Identifies the existing features of the 
Central Valley Project and State Water 
Project that are recognized in the 
Agreement . 



Article 6, Coordination of Operations 

This article is the heart of the Agree- 
ment. It specifies how, and in v*iat 
proportions, the two projects will: 



Share available water supplies; 

Share responsibilities to maintain 
Sacramento Valley in-basin use. 

The sharing of water supplies and 
responsibilities is controlled by nego- 
tiated sharing formulas. These formulas 
were determined with the aid of studies 
in which the two projects were operated 
(on paper) to produce the 1980-level 
project supplies stated in Exhibit B-1 . 

The sharing formulas are structured 
around the necessity to meet the 
in-basin use requirements. As defined 
in Subarticle 3(a), in-basin use is all 
use of water of the Sacramento River 
system in the Sacramento Valley and the 
Delta, and it includes the Delta outflow 
and water quality requirements specified 
by Exhibit A of the Agreement. The 
Exhibit A requirements, extracted from 
State Water Resources Control Board 
Decision 1485, vary according to year 
types classed as "wet, above normal, 
below normal, dry, and critical" and 
according to time of year within the 
year types. 

The amount and timing of in-basin use is 
not known to or controlled by the 
project operators and cannot be readily 
measured, but the Delta is downstream 
from all other in-basin uses, and com- 
pliance with the Exhibit A requirements 
or "standards" for the Delta can be 
monitored. If the Exhibit A standards 
are being met, all other in-basin use 
requirements are being met, because the 
Delta gets only the water that remains 
after upstream uses have been 
sat isf ied . 

When water is plentiful in the Sacra- 
mento River system, the projects can 
store and export water to their full 
capabilities, and in-basin use require- 
ments will still be met. But as runoff 
subsides, a time comes when water must 
be allocated among the two projects and 
in-basin uses. This time is signalled 
when conditions in the Delta approach 
the Exhibit A standards. When the Delta 



reaches Exhibit A conditions, known as 
"balanced water conditions," the Bureau 
and the Department operate their proj- 
ects by a sharing formula to maintain 
those conditions. Balanced water condi- 
tions occur in all but a few very wet 
years. Typically, balanced conditions 
begin in late spring and continue 
through early fall. 

The projects have two mechanisms for 
maintaining balanced conditions: their 
reservoir releases, and their Delta 
exports. Reservoir releases plus any 
other water that reaches the Delta must 
provide enough water to meet Exhibit A 
and export requirements. The operators 
adjust the water needed to meet 
Exhibit A by increased reservoir 
releases, reduce exports, or both. 

There are two kinds of reservoir 
releases during balanced conditions: 

Pass-through flows , which occur when 
the rate of inflow to the reservoir 
equals or exceeds the rate of outflow, 
causing either no net change or a net 
increase in reservoir storage. 

Storage withdrawals , which occur v^ien 
the rate of outflow from a reservoir 
exceeds the rate of inflow, causing a 
net decrease in reservoir storage (a 
use of water that had been stored). 

Sometimes, to maintain balanced condi- 
tions, the projects need only reduce 
either exports or the rate at which they 
are increasing reservoir storage; but as 
natural flows diminish, they must start 
making storage withdrawals to sustain 
their exports and provide the water 
required for in-basin use. 

The sharing formula applies to two 
different situations that occur during 
balanced water conditions. One 
situation apportions the responsibility 
for making storage withdrawals to supply 
in-basin uses v^en flow other than from 
storage withdrawals (unstored flow) is 
insufficient to provide the full supply 
required to meet Exhibit A standards and 



Delta export demands. The formula for 
sharing this responsibility is: 

Central Valley Project 75 percent 
State Water Project 25 percent 



The other situation defines the rights 
of the two parties to store or export 
water when unstored flow is available in 
excess of in-basin use requirements 
(including Exhibit A). The formula for 
sharing this water is: 

Central Valley Project 55 percent 
State Water Project 45 percent 



The formula is applied on a daily basis. 

Figure 2 is a simplified illustration of 
how the formula operates — simplified 
in that it assumes a smooth decline and 
buildup of runoff, constant export 
levels, and constant in-basin use 
requirements. The left side of the 
figure represents conditions as they 
might exist in the spring, when periods 
of balanced conditions often begin: 
project exports plus additions to proj- 
ect storage take all the unstored flow 
that is excess to in-basin use require- 
ments. They take it both by exporting 
from the Delta and storing in their 
reservoirs. The Central Valley Project 
is entitled to 55 percent of the avail- 
able excess; the State Water Project to 
45 percent . 

As unstored flow declines with decreas- 
ing runoff, additions to project storage 
must decrease to maintain exports and 
in-basin use. On a certain day, repre- 
sented by line A-A ' on Figure 2, no 
water is available to add to storage, 
and withdrawals from storage must begin 
thereafter to maintain exports. Until 
the day represented by line B-B ' , each 
project may export an amount of water 
equal to its storage withdrawal plus its 
share (as determined by the 55:45 
formula) of unstored flow in excess of 
in-basin use requirements. 



On day B-B', there is no longer any 
excess unstored flow to contribute to 
exports or to be shared 55:45, and 
exports equal storage withdrawals. 
Thereafter, storage withdrawals must be 
increased to exceed exports in the 
amount that allows in-basin use 
requirements to be fully met. The 
responsibility to make such storage 
withdrawals for in-basin use is borne by 
the Central Valley Project and State 
Water Project in the proportions 75:25. 
While the 75:25 formula is in effect, 
both projects are entitled to export an 
amount equal to their storage with- 
drawals, less their allocated contribu- 
tions to in-basin use. 

As unstored flow increases in fall and 
early winter, the steps are reversed. 
The early increases in unstored flow 
eliminate the need for storage withdraw- 
als to meet in-basin use, and the 75:25 
formula goes out of effect. The 55:45 
formula then takes over to apportion 
excess unstored flow. Finally, unstored 
flow exceeds the sum of in-basin use, 
exports, and additions to storage, and 
neither formula is needed; "excess water 
conditions" exist. 

In actual operation, the progression of 
events would not be so smooth as is 
indicated by Figure 2. In-basin use 
requirements change throughout the year , 
as do export levels, and runoff varies 
in a less regular pattern. Applied on a 
daily basis, the formula is able to take 
these variations into account. Table 1 
illustrates operation of the sharing 
formula through a period of balanced 
water conditions with exports, storage, 
in-basin use, and unstored flow all 
varying. The table condenses an entire 
period of balanced conditions into six 
representative days, illustrating how 
the sharing formula operates and how 
records would be kept to assure that 
water and responsibilities are being 
shared according to the formula. 

The sharing formula applies unless one 
project's storage withdrawal or unstored 



FIGURE 2 UNSTORED FLOW AND STORAGE WITHDRAWALS 
UNDER BALANCED WATER CONDITIONS 



ADDITION 

TO 
STORAGE 



O 




REQUIREMENTS 



UNSTORED FLOW 



^^g UNSTORED FLOW AVAILABLE FOR PROJECT EXPORT OR STORAGE 
'A7-7\ (Shared 55% for CVP, 45% for SWP) 



'v^ 




STORAGE WITHDRAWAL 

STORAGE WITHDRAWAL TO MEET IN-BASIN USE REQUIREMENTS 
(Responsibility shared 75% CVP, 25% SWP) 



10 



TAle 1 

APPLICATION OF ThC COORDINATED OPERATION AGREEMENT SHARING FORMULAS 

OVER 6 REPRESENTATIVE DAYS OF BALANCED WATER COWITIONS* 

(Values in Acre-Feet) 

^ne Note Description Day A Day B Day C Day D Day E Day F 

1 1 CVP Storage 1,000 -100 -1,000 -400 -100 300 

2 CVP Export 1,200 800 500 500 500 400 

3 2 CVP Subtotal TTTTO ""TDD' "^^^OB ~Tm "~51IT ~^fm 

4 3 SWP Storage 1,000 -200 -1,200 -500 -100 300 

5 SWP Export 1 ,500 800 400 300 600 560 

6 4 SWP Subtotal 7750D ~~Sm ~33DD "^TUn ~TDD ~555 

7 5 TOTAL 4,700 1,300 -1,300 -100 900 1,560 



Description 


CVP 
CVP 
CVP 


Storage 

Export 

Subtotal 


SWP 
SWP 
SWP 


Storage 

Export 

Subtotal 


TOTAL 


Formula 


CVP 


Share 


SWP 


Share 


CVP 
SWP 


Discrepancy 
Discrepancy 


CVP 


Balance 


SWP 


Balance 



8 Formula 55:45 55:45 75:25 75:25 55:45 55:45 

9 6 CVP Share 2,585 715 -975 -75 495 858 

10 6 SWP Share 2,115 5B5 -325 -25 405 702 

11 7 CVP Discrepancy +385 +15 -475 -175 +95 +158 

12 8 SWP Discrepancy -385 -15 +475 +175 -95 -158 

13 9 CVP Balance +385 +400 -75 -250 -155 +3 
1* 10 SWP Balance -385 -400 +75 +250 +155 -3 

NOTES: 1 CVP storage is the combined inflow to its reservoirs in the Sacramento Valley basin 

minus the combined outflow from those reservoirs and all imports to the Sacramento 
Valley basin from the Trinity River. Negative values indicate net storage withdrawals 
by the CVP. Ftositive values indicate net increases in CVP storage. 

2 Positive values indicate a net use of unstored flow by the CVP. Negative values 
indicate in-basin use of CVP storage withdrawals. 

3 SWP counterpart of Line 1. SWP has only one major reservoir, Oroville, and no imports 
to the basin. 

4 SWP counterpart of Line 3. 

5 Positive total indicates a net use or capture of instored flow by the two projects 
combined, which means the 55:45 formula is applicable. Negative total indicates net 
use of storage withdrawal for in-basin use, viHiich means the 75:25 formula is 
applicable. 

6 line 7, Total, allocated according to Line 8, Formula. 

7 Line 9, CVP Share, minus Line 3, CVP Subtotal. 

8 Line 10, SWP Share, minus Line 6, SWP Subtotal. 

9 CVP balance frum previous day (assumed to be zero on Day A) plus Line 11, CVP 
Discrepancy, for current day. 

10 SWP balance from previous day (assumed to be zero on Day A) plus line 12, SWP 

Discrepancy, for current day. 

* Values in this table indicate volumes of water that are representative of actual operation only in the 
sense that the mathematical relationships between the values are in accordance with the sharing 
formulas. Days represent situations that might occur through the course of a season of balanced water 
conditions. These situations would be likely to occur in the order presented, but not on consecutive 
days. Days A to F in the table are presented as consecutive to show how balances are carried from one 
day to the next . 



11 



flow available for export exceeds its 
export capability. In this event, the 
excess storage withdrawal or unstored 
flow may be exported by the project that 
has the capability to do so, without 
affecting either project's future 
responsibilities or daily balance. 



Article 7, Forecasting 

Requires each party to furnish to the 
other, upon request, a forecast of 
operat ions . 



Article 8, Water Measurement 
Responsibilities 

Requires that the measurements necessary 
to implement Article 6 be made by each 
party. 



Article 9, Reduction in United States 
and State Exports 

Provides that the two parties shall 
discuss measures to minimize water 
shortages for export users whenever such 
shortages are forecast. 



Article 10, Exchanges, Conveyance, and 
Purchase of Water Supply 

Section (a) says either party may pump 
and convey (wheel) water for the other 
party by written agreement. 

Section (b) has to do with wheeling to 
compensate the CVP for the pumping it 
must forego at its Tracy and Rock Slough 
pumping plants in observance of 
Exhibit A. Exhibit A requires that CVP 
diversions from the Delta (through the 
two pumping plants) be limited to a 
maximum mean monthly rate of 3,000 cubic 
feet per second (cfs) during May and 
June of each year. This limitation and 
corresponding SWP pumping limitations to 
3,000 cfs in May and June and 4,600 cfs 
in July are intended to minimize the 
diversion of young striped bass from the 



southern Delta in the season v*ien they 
are most numerous there. The SWP has 
excess capacity for pumping from the 
Delta, while the CVP does not. Under 
Section (b) the SWP would use its excess 
capacity to pump, at some time prior to 
April 30 of the following year, up to 
195,000 acre-feet of water foregone by 
the CVP during May and June. 

Subsections under (b) assure that the 
CVP will supply power in accordance with 
Exhibit D for the wheeling described in 
(b) and that this v^ieeling shall be done 
in an economical manner. The State 
requires that the United States (CVP) 
pay certain incremental costs associated 
with v^eeling. 

Sections (c) through (g) specify 
wheeling arrangements applicable to 
situations in v^ich facilities of the 
CVP or SWP are inoperative due to 
scheduled or unscheduled maintenance. 
The SWP will wheel for the CVP in such 
situations, provided that the CVP 
supplies the necessary power and pays 
certain charges. The CVP will v^eel for 
the SWP in such situations, with the 
understanding that it will be repaid for 
this service by the wheeling of an equal 
quantity of water for the CVP by the SWP 
at a later time. 

Section (h) requires the parties to 
promptly begin negotiations toward a 
contract for SWP wheeling of CVP water 
beyond that contemplated in the preced- 
ing sections of Article 10. The vAieel- 
ing contemplated in Section (h) would 
increase the water supply delivery capa- 
bility of the CVP. The same contract 
would also include terms under v«*iich the 
CVP would sell water to the SWP. 
Purchases from the CVP would increase 
the SWP's water supply for an interim 
period . 



Article 11, Delta Standards 

Exhibit A sets forth the Delta standards 
for fish and wildlife and water quality 
that are considered part of Sacramento 



12 



Valley in-basin use and are, therefore, 
a key element of the Agreement. 
Article 11 gives force to the Exhibit A 
standards by saying that the Central 
Valley Project and the State Water 
Project will be operated in conformity 
with these standards. This article also 
describes how the Federal Government 
will respond if the State Water 
Resources Control Board establishes new 
Delta standards that are different from 
Exhibit A. Federal decision-makers will 
determine whether operation of the CVP 
in conformity with the new standards 
would be inconsistent with Congressional 
directives. If they determine that 
operation of the CVP to meet the new 
standards would not be inconsistent with 
(contrary to or in conflict with) Con- 
gressional directives. Exhibit A will be 
amended to conform to the new standards. 
If it is found that operation of the CVP 
in conformity with the new standards 
would be inconsistent with Congressional 
directives, the Bureau will promptly 
request that the Department of Justice 
bring a legal action to determine 
whether the new Delta standards should 
be considered legally binding on the 
CVP. 

This article further provides that the 
Bureau reserve the right to seek legis- 
lation regarding operation of the CVP 
including compliance with any new Delta 
standards and the Agreement does not 
infer any additional authority on the 
Secretary of the Interior or the State 
Water Resources Control Board. 



Article 12, Monitoring 

Exhibit C describes the monitoring 
activities for ensuring compliance with 
the Delta standards of Exhibit A. 
Article 12 provides that the parties 
will share equally the cost of such 
monitoring. It also allows for 
amendment of Exhibit C if necessary. 
Additional monitoring in the Delta and 
San Francisco Bay will be covered by 
separate agreements. 



Article 13, Records 

Allows each party full access to books 
and records of the other party insofar 
as they pertain to the Agreement. 



Article 14, Periodic Review 

Establishes general guidelines for joint 
review of operations of both projects. 
Such a review will occur every 5 years, 
or more frequently if requested by 
either party. The factors and proce- 
dures in Article 6, Exhibits B-1 , B-2, 
and D, and the operations study used to 
develop Exhibits B-1 and B-2 will be 
revised when necessary. If the parties 
are unable to agree on revisions, or 
fail to enter into the contract 
described in subarticle 10(h) by 
December 31, 1988, this article further 
specifies a negotiating procedure that 
includes a requirement to refer the 
problem to a 3-member advisory Board. 
If the board fails to make a unanimous 
recommendation within 24 months from the 
notice of negotiations in the case of 
the revisions, or 12 months for the 
contract, either party may unilaterally 
terminate the Agreement. 



Article 15, Relation to Agreement 
of May 16, 1960 

Suspends the agreement of May 16, 1960, 
so long as the new Agreement remains 
in force. Upon termination of the new 
Agreement, the May 16, 1960, agreement 
is automatically reinstated. 



Article 16, New Facilities 

Establishes principle that any yield 
created by construction of a new 
facility will be credited to the party 
that constructs the facility, or to both 
parties in the case of a joint 
undertaking. When a new facility is 
constructed, a review of the Agreement 
is required pursuant to Article 14. 



13 



Article 17, Project Service Area 



Exhibit A 



Each party agrees to respect the other's 
project service areas. 



Article 18, Third Party Rights 
Unaffected 

Acknowledges that the Agreement is not 
intended to affect the rights of third 
parties . 



Article 19, Effect of 
Waiver of Breach 



This is the set of flow and water 
quality standards that define the Delta 
portion of in-basin use requirements. 
The standards are identical to the Delta 
water quality and flow standards of the 
State Water Resources Control Board's 
Decision 1485, except that the standards 
for Suisun Marsh that were to become 
effective in 1984 are omitted. The 
significance of Exhibit A is explained 
in the discussion of Article 6 and later 
in this chapter under "Analysis of 
Accomplishments of the Agreement". 



Acknowledges that the rights of the 
parties under the Agreement are not 
affected if either party fails to object 
to a breach of the Agreement by the 
other party. 



Article 20, Equal Emplojrment 
Opportunities 

The State agrees to standard provisions 
regarding treatment of employees and 
prospective employees without regard to 
race, color, religion, sex, or national 
origin. 



Article 21, Contingent Provisions 

Conditions performance of the parties on 
availability of funds. 



Article 22, Officials Not to Benefit 

Precludes certain Federal and State 
officials from deriving private benefit 
from the Agreement . 



Exhibits of the Agreement 

This section reviews the six Exhibits of 
the Agreement . 



Exhibits B-1 and B-2 

These exhibits state annual water 
supplies for the Central Valley Project 
and State Water Project. Annual water 
supply is defined as the amount of water 
a project can deliver through a 7-year 
dry period such as occurred from 1928 to 
1934, taking into account the allowable 
deficiencies. Deficiencies (delivery of 
less than the stated annual supply) are 
allowable, subject to certain condi- 
tions, as long as their total over the 
7 years does not exceed 100 percent of 
the stated annual supply. 

In developing the annual water supply 
figures, the Central Valley Project was 
allowed no more than a 25 percent 
deficiency in any year. The State Water 
Project was allowed no more than a 
50 percent deficiency for its agricul- 
tural contractors in any year and no 
deficiencies for municipal and indus- 
trial contractors. The significance of 
Exhibits B-1 and B-2 is discussed later 
in this chapter under "Analysis of 
Accomplishments of the Agreement". The 
detailed derivation of the annual water 
supply figures is the subject of the 
"Technical Report on Determination of 
Annual Water Supplies for Central Valley 
Project and State Water Project", dated 
March 1984, This document is reproduced 



14 



in part as Appendix G of this report. 
The complete text, including operation 
studies, is available from the 
Department or the Bureau. 



Exhibit C 

This exhibit specifies 18 locations in 
the Delta where electrical conductivity 
measurement stations will be maintained 
to monitor compliance with the Exhibit A 
standards. Electrical conductivity is a 
measure of the concentration of mineral 
salts in water. 



Exhibit D 

This exhibit specifies the procedure by 
which the Bureau of Reclamation, as 
operator of the CVP, will provide the 
energy required to wheel its water 
through the SWP's Harvey 0. Banks Delta 
Pumping Plant when such wheeling is 
necessary to make up for pumping 
foregone by the CVP in observance of the 
May-June pumping restrictions of 
Exhibit A. 

Although CVP water will not be wheeled 
at the Banks plant during May and June, 
the CVP will have the option to provide 
the SWP with energy during those months 
in any amount up to what would be 
required for all the pumping it is fore- 
going because of the Exhibit A pumping 
restrictions. In recognition of the 
CVP ' s energy contribution (if any), the 
SWP will establish a CVP energy account 
in dollars and based on the value of the 
CVP energy at the time it is received. 
The SWP will use the value residing in 
this account as credit against its cost 
for the energy required to wheel the 
CVP's makeup water when the wheeling 
actually occurs. Should the account be 
insufficient to cover the cost of all 
the energy required, the CVP may supply 
the balance in the form of energy. 

Alternatively, the CVP may elect not to 
establish an energy account with the 
SWP, and instead supply all the 



necessary energy v*ien v*ieeling is 
occurring. 



Exhibit E 

This exhibit specifies the deficiency 
provisions applicable to any sale of CVP 
water to the SWP that may occur under 
the contract referred to in Article 
10(h). The language in this Exhibit is 
taken from a recently executed CVP water 
service contract. When the CVP, because 
of drought or other reason beyond its 
control, does not have enough water to 
fully meet its contracts, including any 
contract it may make with the State, it 
imposes deficiencies; i.e., the 
contractors get less than their full 
contractual supplies. In general, the 
available supplies are apportioned by 
reducing deliveries to all contractors 
by the same percentage, regardless of 
whether the contractor buys water for 
agricultural or municipal/industrial 
use. 



Analysis of Accomplishments 
of the Agreement 

The preceding sections reviewed the 
articles and exhibits of the Agreement. 
This section discusses the overall sig- 
nificance of the Agreement, vAiich would: 

Commit both the Central Valley Project 
and the State Water Project to meeting 
water quality and outflow standards 
for the Delta that are equivalent (at 
least as far as the Delta is con- 
cerned) to the State Water Resources 
Control Board's Decision 1485 
standards . 

Establish mutually recognized annual 
water supplies of the two projects. 

Establish a new sharing formula. 

Firm up certain arrangements for 
wheeling and require negotiations 
toward purchase and additional 
wheeling of CVP water. 



15 



Delta Water Quality and 
Outflow Standards 

State law requires the State Water 
Project to be operated in compliance 
with Delta standards established by the 
State Water Resources Control Board. 
The State has always maintained that the 
U. S. Bureau of Reclamation is obligated 
Co operate the Central Valley Project to 
meet the same standards. The Bureau 
maintains that the current State 
standards are not binding on the Central 
Valley Project and that water quality 
protection in the Delta is not an 
authorized purpose of the CVP. 

The State Water Resources Control Board 
adopted the current Delta standards in 
its Decision 1485 (August 1978). On 
January 3, 1979, the Secretary of the 
Interior announced that his agency (of 
which the United States Bureau of 
Reclamation is a part) would voluntarily 
meet the State Board's standards for the 
Delta; however, there were two 
conditions: 

The Secretary's commitment to meet 
standards was to remain in effect only 
until the legal question of mandatory 
Federal compliance was settled by 
Congress or the courts. 

This commitment did not extend to 
years of extraordinary drought, such 
as 1977. 

So, at the beginning of negotiations 
toward the present draft Coordinated 
Operation Agreement in 1979, the Bureau 
viewed its obligation to meet State 
standards in the Delta as limited and 
conditional and only the expressed 
policy of the Secretary of the Interior, 
not a binding legal obligation. That 
situation has not changed. 

The Bureau considers its only binding 
legal commitments regarding Delta water 
quality to be those contained in the 
water quality provisions of its water 
rights exchange contracts with water 
users in the lower San Joaquin basin. 



In these contracts, the Bureau agrees to 
supply water of specified qualities via 
its Tracy Pumping Plant. If the draft 
Coordinated Operation Agreement were not 
signed, the Bureau could attempt to 
operate only for these "Tracy standards" 
in an extreme drought year under its 
current policy, and in any other year if 
that policy were changed by the 
Secretary of the Interior. The Tracy 
standards are less demanding on project 
operations and not as comprehensive as 
those of Decision 1485. 

Because the State Water Resources 
Control Board holds the Central Valley 
Project and State Water Project jointly 
responsible for maintaining Delta 
standards, any possibility that the 
Central Valley Project will not be 
operated to provide its share of the 
water needed to meet these standards 
represents a serious concern for the 
State Water Project. The Department of 
Water Resources might have to make up 
the Central Valley Project share with 
the State Water Project's limited and 
fully committed water supplies, or else 
petition the State Water Resources Con- 
trol Board for relief. The consequences 
of the Central Valley Project not being 
operated to meet Delta standards are 
elaborated upon in Chapter 4. 

In executing a Coordinated Operation 
Agreement as drafted, the Central Valley 
Project and State Water Project would 
obligate themselves to meet the Delta 
standards contained in Exhibit A of the 
Agreement. The Exhibit A standards are 
taken from Decision 1485, although 
certain standards for the Suisun Marsh 
have been omitted. The reasons for and 
significance of this omission are 
discussed in Chapter 3 under "Modified 
Agreement". 

The commitment by the parties to meet 
the Exhibit A standards is an environ- 
mental commitment inherent in the 
Proposed Action, 

The Agreement would not commit the 
Bureau to accept any future Delta 



16 



standards that may replace or supersede 
those of Decision 1485. If such new 
Delta standards were established, 
Federal decision-makers would determine 
whether operation of the CVP to meet the 
new standards would be inconsistent with 
Congressional directives. If they 
determine that operation of the CVP to 
meet the new standards would not be 
inconsistent with (contrary to) Congres- 
sional directives, Exhibit A would be 
amended to conform to the new standards, 
and both projects would operate accord- 
ingly. If the decision-makers determine 
that operation of the CVP to meet the 
new standards would be inconsistent with 
Congressional directives, the Bureau 
must promptly ask the Department of 
Justice to bring a legal action to 
determine the applicability of the new 
standards to the CVP. 



Annual Water Supplies 

The Agreement estimates mutually recog- 
nized annual water supplies of the 
Central Valley Project and State Water 
Project, in Exhibit B-1 for 1980 and in 
Exhibit B-2 for "full development". 
Development relates to demand for water, 
not to development of project facili- 
ties. These supplies were computed 
using mathematical procedures wherein 
the operational capabilities of existing 
facilities of the two projects are 
superimposed on sets of conditions 
representing a level of development , 
demand for water from the projects, and 
naturally occurring hydrology. 

The water supply computations reflect a 
priority concept that is an important 
assumption of the Agreement. Under this 
assumption, the CVP facilities built 
before the State Water Project are 
assumed as having whatever water supply 
yield they would have if the later 
projects had not been built. The State 
Water Project and the CVP's San Luis 
Unit are then considered to have equal 
claims on the remaining water. 



The supplies computed for 1980, 
6.9 million acre-feet for the Central 
Valley Project and 3.7 million acre-feet 
for the State Water Project, were used 
in deriving the sharing formulas of 
Article 6. The 75:25 formula was 
carried over from the previous draft 
Coordinated Operation Agreement, and was 
regarded by negotiators for both 
agencies as fair, considering the much 
larger portion of the Sacramento basin 
that lies downstream from Central Valley 
Project storage facilities. The 55:45 
formula is geared to realizing the 
1980-level supplies of Exhibit B-1 for 
both projects through a period of 
relative drought, such as occurred from 
1928 to 1934. 

Exhibit B-2, vrfiich is based on the year 
2020, illustrates how much water each 
project may have at its full development 
level under principles and assumptions 
accepted by negotiators of the Agree- 
ment as valid for illustration purposes. 
Central Valley Project supplies are 
higher for 2020 than for 1980, because 
for 2020 it is assumed that the CVP is 
making full use of water it can right- 
fully claim and deliver to existing or 
potential contractors without new yield- 
augmenting facilities. State Water 
Project supplies are lower for 2020 than 
for 1980, partly because much of the CVP 
increase in supply over the same time 
span represents water that the SWP was 
using at the 1980 level. The State 
Water Project was using this water 
because the Central Valley Project 
lacked either the demand for it or the 
means to deliver it. As Central Valley 
Project demands and deliveries increase 
upstream from the Delta, less water 
reaches the Delta for export by the 
State Water Project. 

The CVP year 2020 annual supply stated 
in Exhibit B-2 is subject to reduction 
by the commitment of additional water 
for fish protective flows in the Trinity 
River (see discussion in Chapter 4 under 
"Other Projects and Actions"). 



17 



By quantifying water supplies, 
Exhibits B-1 and B-2 (particularly B-2) 
may represent a step in the direction of 
allowing the Central Valley Project to 
enter new contracts. If the Central 
Valley Project is to realize its full 
development water supply, it will have 
to make new contracts and serve new 
areas. However, the connection between 
the Coordinated Operation Agreement and 
any potential new contracts is tenuous. 
First, the Coordinated Operation 
Agreement is not a prerequisite to such 
contracts; new Central Valley Project 
contracts may be signed with or without 
the Coordinated Operation Agreement. 
Second, Exhibit B-2 is included in the 
Agreement more to establish the posi- 
tions of each party with respect to the 
rights of the other party than to indi- 
cate a physical presence of contractable 
water. Whatever water is physically 
available in the system is available 
regardless of the Agreement. Third, the 
Agreement would not trigger any new 
contracts; each contract would be a 
separate and independent action subject 
to studies on water availability and 
environmental impact. 



Sharing Formula 

The operators of the Central Valley 
Project and State Water Project consider 
the new formula for sharing unstored 
flow more fair and workable than the 
formula used previously. 

An important difference between the new 
and old formulas is that in the 
situation of balanced water conditions 
where storage withdrawals are not 
required to maintain in-basin use, the 
new formula allocates all the unstored 
flow available to the projects, 
including that being put into storage. 
The old formula allocated only the 
unstored flow available for export in 
the Delta; it did not allocate inflow to 
either project's reservoirs that could 
have been unstored flow available for 
export had the project chosen to release 
(pass it through) rather than store it. 



This omission in the old formula allowed 
at least the potential for, if not the 
actual accomplishment of, schemes to 
increase one project's exportable water 
supply at the expense of the other 
project. In such schemes, the strategy 
would be to avoid releasing water from a 
reservoir unless the release could be 
counted as a storage withdrawal. This 
strategy could be effective because the 
full amount of a storage withdrawal 
could be exported by the project that 
made it, but any other release had to be 
shared. With its smaller delivery 
obligations, lesser inflow, and higher 
pumping and conveyance capability, the 
State Water Project was in the best 
position to profit from this strategy. 
With limited export pumping capability 
in the Delta, the Central Valley Project 
sometimes might need to reduce its rate 
of storage upstream to sustain its 
maximum export level. Reduction in the 
Central Valley Project storage rate 
would take the form of releases, and 
these would count as exportable unstored 
flow v*ien they reached the Delta. 

The old agreement had a complicated 
formula for calculating shares of 
exportable unstored flow, but the State 
Water Project was usually entitled to 
60 percent. Thus, for an acre-foot of 
unstored flow released to maintain its 
exports, the Central Valley Project 
could actually export only four-tenths 
of an acre-foot, with the other six- 
tenths going to State Water Project 
export if the SWP operated to take full 
advantage of the CVP ' s predicament. 

The Central Valley Project was perhaps 
disadvantaged, but certainly not 
defenseless, under the old formula. 
With its multiple reservoirs, it had, at 
least in theory, the capability to 
minimize exportable unstored flow in the 
Delta by drawing down one reservoir at a 
time. This would force the State Water 
Project into greater reliance on its own 
storage withdrawals. Also, if the 
operators of the CVP believed their 
project was suffering under a 
disadvantage in operating by the old 



sharing formula, they were never under 
an obligation to abide by it for more 
than one year at a time. 

The new sharing formula for allocating 
unstored flow, because it applies to all 
unstored flow whether available in the 
Delta or not, assures that this prized 
commodity will be shared in the propor- 
tions specified. 



Wheeling Arrangements 

Sometimes one or the other project needs 
to have some of its water conveyed 
(wheeled) in facilities of the other 
project. Article 10 of the new 
Agreement provides an arrangement to 
cover wheeling in certain situations. 
These situations occur during outages in 
the facilities of either project and 
whenever the Central Valley Project has 
had to curtail export pumping at the 
Delta (per Exhibit A requirements) to 
minimize diversion of young striped bass 
during May and June. 

Under Article 10, wheeling can be done 
on a more reliable basis, because 
compensation for the wheeling party is 
already negotiated and predetermined. 
The terms of compensation are similar to 
what have been used in the past. 

The wheeling specifically provided for 
by the Agreement is limited to certain 



situations. This limited \«heeling 
facilitates maintenance of current 
levels of water service from the Delta 
by the SWP and CVP. 

The v^eeling to be discussed in the 
required negotiations could increase the 
capability of the CVP to export water 
from the Delta. The required negotia- 
tions would also deal with proposed 
purchases of water from the CVP by the 
SWP. The SWP faces water delivery 
obligations in excess of its current 
capabilities and needs additional water 
supplies to meet these obligations. Any 
water the SWP might be able to purchase 
from the CVP would be supplied to the 
SWP's Clifton Court Forebay for export 
from the Delta at the Harvey 0. Banks 
Delta Pumping Plant. 

The effect of the Agreement is to 
require the negotiations and not to 
institute the wheeling and water 
purchase arrangements that will be the 
subject of the negotiations. However, 
Congressional ratification of the 
Agreement will resolve the situation 
created by the Secretary's 1978 decision 
to temporarily suspend further water 
service contracting until the 
applicability of Exhibit A standards to 
the CVP was resolved. Therefore, upon 
ratification, the CVP's objective to 
implement a full-scale water marketing 
program of its available supplies can be 
implemented . 



19 



Chapter 3. ALTERNATIVES 



As ia any other proposed agreement 
resulting from a negotiation process, 
the parties have three options in addi- 
tion to the no agreement option: accept 
the agreement, reject the agreement, or 
continue to negotiate. Accordingly, the 
following three alternatives are con- 
sidered in this report: 

The Proposed Action; representing the 
parties' option to accept the proposed 
Agreement. Consideration of the 
Proposed Action as an alternative is 
required under the National Environ- 
mental Policy Act. 

No Action; representing the parties' 
option to reject the Agreement. No 
Action is also an alternative required 
by NEPA. It is assumed in the No 
Action alternative that the Central 
Valley Project and the State Water 
Project would continue to coordinate 
their operations, although without a 
long-term agreement. 

Modified Agreement; representing poss- 
ible outcomes of resumed negotiations. 
Executing a modified agreement may be 
considered an alternative to the Pro- 
posed Action as long as the agreement, 
as modified, fulfills the "Need for 
Action" described in Chapter 1. 

The no agreement option is also consid- 
ered. This alternative represents a 
complete breakdown in coordination of 
the two projects. 

The Proposed Action and No Action were 
studied in more detail than the other 
alternatives. They are evaluated in 
Chapter 4, and that evaluation is 
summarized in this chapter. 



Alternative 1, 
The Proposed Action 

The Proposed Action, signing and imple- 
menting the draft Coordinated Operation 
Agreement, is described in Chapter 2. 
Under the Proposed Action the Central 
Valley Project and State Water Project 
would continue to operate as they have 
in recent years, although using a diff- 
erent sharing formula. The new sharing 
formula would not result in physically 
observable changes. The Delta water 
quality and outflow standards of the 
Agreement's Exhibit A would be binding 
on both projects in all years. 



Alternative 2, No Action 

If the Proposed Action (or some action 
like it) is not taken, and until it is 
taken, the Bureau or DWR will probably 
enter agreements each year to operate 
according to the terms of the draft 
Agreement for that year only. This 
would be consistent with the past 
practice of agreeing annually to operate 
according to the terms of the unsigned 
draft 1971 agreement, modified to 
include the Delta water quality and 
outflow standards of Decision 1485. 

The main environmental difference 
between taking the Proposed Action and 
not taking it (No Action) is that 
without the Proposed Action, each year 
represents an independent decision point 
at vAiich the Bureau of Reclamation might 
not agree to operate the CVP in accord- 
ance with the Delta water quality and 
outflow standards of the Agreement's 
Exhibit A. The Exhibit A standards are 
taken from Decision 1485. 



21 



Current Bureau policy, announced by 
Secretary of the Interior Cecil D. 
Andrus on January 3, 1979, is that the 
Bureau will meet the Decision 1485 
standards in all but "years of extra- 
ordinary drought, such as occurred in 
1977" /3/. This policy could be changed 
by another secretarial decision. 

Should the Bureau decide in any year, 
not to meet the Decision 1485 standards 
for the Delta, it would still be obli- 
gated to meet the CVP's own standards 
for the quality of water pumped at the 
Tracy Pumping Plant in the southern 
Delta. These "Tracy standards" are 
contained in the Bureau's contracts with 
users of water from the Delta-Mendota 
Canal. The contracts set the following 
average salinity requirements in total 
dissolved solids (TDS) per liter: 



Annually 

Monthly 

Daily 



TDS 

450 
600 
800 



Evaluation of the No Action alternative 
is based on an assumption that the 
Bureau would operate the CVP to meet 
only the Tracy standards rather than 
those of Exhibit A or Decision 1485 
during critical type water supply years. 
In all other years, the CVP would be 
operated to meet the Exhibit A stand- 
ards. About one-seventh to one-eighth 
of the historical water years for which 
good records are available have been dry 
enough to be considered critical by the 
most commonly used standard, the Four 
Rivers Index; however, the assumption 
that the Bureau would operate for Tracy 
standards was made only for critical 
years in which the Bureau would have to 
impose water supply deficiencies on CVP 
contractors. Most, but not all of the 
historical critical years were dry 
enough to require that action. 

The assumption that the CVP would be 
operated for Tracy standards in critical 
years should not be taken to imply that 
Bureau policy is or would be to so 



operate. Current Bureau policy is to 
operate to meet the Decision 1485 stand- 
ards in ordinary critical years and to 
consider not meeting these standards 
only in years such as 1977, the driest 
year of record. 

If the Bureau were operating the CVP for 
Tracy standards in critical years, it is 
uncertain how the Department would oper- 
ate the SWP in those years. The Board's 
Decision 1485 says: 

"The effect of the Delta Plan and this 
decision is that water quality stand- 
ards in the Delta must be satisfied 
prior to any export from the Delta to 
other areas for any purpose. These 
standards must be maintained as first 
priority operating criteria for any 
and all projects or parts thereof that 
may be constructed and operated under 
the permits considered in this 
decision," 

The permits considered are those of the 
SWP and CVP. One interpretation of this 
passage is that the SWP is fully respon- 
sible to meet the Board's standards 
whether the CVP participates in meeting 
them or not. However, the SWP's water 
supplies are limited and fully committed 
even when the CVP is fully participating 
in the maintenance of the Delta stand- 
ards. Without CVP participation in 
critical years, the capabilities of the 
SWP to meet its obligations to water 
contractors and the Delta would be 
limited, and the Department might 
petition the Board for relief. 

The outcomes of such a petition could 
range from no relief to a complete 
relaxation of Delta standards such that 
the CVP's Tracy standards would control 
in critical years. For the initial 
analysis of the No Action alternative, 
it was assumed that this complete relax- 
ation would occur. Two other cases, in 
which the standards were relaxed 
partially and not at all, were also 
examined. Thus, three cases of the No 
Action alternative were postulated for 
critical years: 



22 



Case A — Both the CVP and the SWP are 
operated to meet only the CVP's Tracy 
standards in the Delta. 



Case B — The CVP is operated to meet 
Tracy standards, while the SWP is oper- 
ated to make the same contribution of 
water for the Delta as it would with the 
Proposed Action, 

Case C — The CVP is operated to meet 
Tracy standards and the SWP is operated 
to meet the Exhibit A standards, con- 
tributing all the extra water required, 
including that v*iich would be the CVP 
share under the Proposed Action. 

For years other than critical years, it 
was assumed in all cases of the No 
Action alternative that both the CVP and 
the SWP would be operated to meet the 
Exhibit A Delta standards. 



Alternative 3, 
Modified Agreement 

If the Department and/or the Bureau 
decided not to execute the proposed 
Agreement, and if negotiations were 
resumed, a modified agreement might 
eventually result. Existing terms of 
the Agreement could be altered, and 
anything could be added on or taken 
away. Discussion here will focus on 
several changes that would still meet 
the purposes of the action described in 
Chapter 1. 



Modifications Within the 
Present Scope 

Modifications in this category would 
not require adding new terms to the 
Agreement. Rather than adding terms, 
the existing terras would be altered. 

Modified Sharing Formulas . Article 6 of 
the Agreement says that during balanced 
water conditions, the responsibility to 
make storage withdrawals will be shared 
in the proportions 75:25 by the Central 
Valley Project and State Water Project, 



respectively; unstored flow for export 
or storage will be shared in the propor- 
tions 55:45. Different proportional 
shares could have been agreed upon. The 
effect of changing the agreed-upon pro- 
portional shares would be to change the 
water supplies of the two projects, and 
probably not in mutually beneficial 
ways . 

The two projects are in much different 
situations in regard to water supplies 
and demands. The Central Valley Project 
has developed water supplies in excess 
of its present demand, and the State 
Water Project faces demands and contrac- 
tual obligations in excess of its devel- 
oped supplies. The sharing formulas in 
the draft Coordinated Operation Agree- 
ment essentially allow the Central 
Valley Project to meet its demands; the 
State Water Project, meanwhile, uses all 
of its own water supplies plus Central 
Valley Project releases that are left 
over after CVP export demands are met. 
Operating the CVP to meet all of its 
current objectives results in surplus 
water in the Delta that the CVP cannot 
use, and this surplus is available under 
the sharing formulas to the State Water 
Project . 

In the storage withdrawal formula, 
higher numbers mean lower water supplies 
for a project. For instance, if the 
Central Valley Project share were 
increased to 80 percent from the 75 per- 
cent in the draft Agreement, Central 
Valley Project water supply reflected in 
Exhibit B-1 would be reduced and State 
Water Project supply would be increased. 
The result of operating according to an 
Agreement with this modification would 
be that the Central Valley Project 
contractors would have less than their 
full supply, and the State Water Project 
contractors could get more water. 

In the unstored flow formula, higher 
numbers mean higher water supplies for a 
project. If the Central Valley Project 
share were increased from the 55 percent 
in the draft Agreement to 60 percent, 
Central Valley Project water supply 



23 



reflected in Exhibit B-1 would be 
increased and State Water Project water 
supply reduced. The result would be 
more water supply than the Central 
Valley Project needs and a greater like- 
lihood and magnitude of deficiencies for 
State Water Project contractors. 

The negotiators of the proposed Agree- 
ment, through detailed studies and 
public negotiations, selected the 55:45 
and 75:25 ratios for Article 6 because 
it struck a balance favorable to both 
projects. Other ratios were considered 
less advantageous for one or both proj- 
ects. Public renegotiations would be 
needed to modify these ratios. It is 
important to recognize that changes to 
the ratios would not change the degree 
of protection of Exhibit A, only the 
sharing of responsibility to meet such 
protection. 

Inclusion of Post-1984 Standards for 
Suisun Marsh . Exhibit A of the Agree- 
ment includes all of the Delta water 
quality and outflow standards of Deci- 
sion 1485 except the ones for Suisun 
Marsh that became effective in October 
1984. The Department and the Bureau, in 
cooperation with other agencies, are 
developing a plan for water quality 
protection in Suisun Marsh /5/. 

Initial facilities providing for partial 
protection of Suisun Marsh have been 
constructed by the Department under a 
contract with the Department of Fish and 
Game and the Suisun Resource Conserva- 
tion District, and a contract for 
construction and operation of more 
extensive Suisun Marsh facilities is 
being negotiated. 

The post-1984 standards for Suisun Marsh 
were not included in Exhibit A because 
it was agreed by the Department and the 
Bureau that the Agreement would contem- 
plate existing facilities only. Also, 
negotiations concerning protection of 
Suisun Marsh were proceeding separately, 
so the marsh was considered a separate 
issue. The Department has prepared a 
Suisun Marsh Plan of Protection, which 



includes an environmental impact report 
/6/. Suisun Marsh protection is 
expected without a specific provision in 
the Agreement, and the Agreement 
includes provisions to incorporate 
future contracts on Suisun Marsh. 
Public renegotiations on the Agreement 
for Suisun Marsh provisions would be 
possible in the future, but would only 
duplicate water quality protection of 
negotiations now underway. 

Modified Exhibit A . The Delta water 
quality and outflow standards of 
Exhibit A have been part of operations 
of both projects each year since they 
took effect in water year 1979. The 
effectiveness of the standards in 
maintaining the Delta fishery resource, 
especially for striped bass, has been 
disappointing. The steady decline of 
the striped bass fishery, observed since 
the 1960s, has not been arrested. 
Resource levels in some other fish 
species also appear to be in decline. 

The reasons for the decline of the Bay- 
Delta fishery are not well understood, 
but some people have suggested that 
combined CVP and SWP operations are at 
least partly at fault. Other concerns 
are toxics and pollution. One way to 
attempt to halt the decline of the Bay- 
Delta fishery would be to change the 
Delta water quality and outflow stand- 
ards applicable to operation of the 
projects. This could be done by 
modifying Exhibit A of the proposed 
Coordinated Operation Agreement. 

The possibility of modifying Exhibit A 
standards was reviewed; however, impor- 
tant points related to this matter must 
be considered: 

The existing standards are the best 
established method to define protec- 
tion . 

The State Water Resources Control 
Board is responsible for changing 
standards, v^ich involves compre- 
hensive public hearings. 



24 



Many studies of the Delta-Bay ecosystem 
or some part of it are underway, and 
knowledge increases every year. So far, 
however, not enough is known to identify 
the conditions causing the fishery 
decline or to determine whether revising 
the Delta standards could arrest or 
reverse it. 

The State Board said that setting the 
Decision 1485 standards involved 
"essentially the allocation of water 
shortages". It also said the Decision 
attempted to strike a balance between 
competing needs. Adjusting the balance 
to give more weight to environmental 
protection — by allocating more water 
for this purpose — would be expected to 
benefit the environment. The benefits 
would be difficult to predict and 
quantify. 

The State Board is aware of the environ- 
mental problems that have been observed 
through the six or so years of operating 
to the Decision 1485 standards, and will 
begin reconsideration of those standards 
in 1986. Revised standards are expected 
by 1988. Article 11 describes how the 
parties to the Agreement will respond 
when revised standards are declared. 

The Modified Exhibit A alternative is 
not considered further in this report 
because an agreement in which the 
Decision 1485 standards are modified in 
an attempt to correct or ameliorate such 
problems as the fishery decline would go 
beyond the underlying purpose and need 
and the objectives intended for the 
Proposed Action. The Proposed Action 
aims to define the respective responsi- 
bilities of the CVP and SWP toward 
meeting existing obligations, not to 
define what the projects' obligations 
should be. 



Modifications That 
Broaden the Scope 

This category is intended for modifica- 
tions that could require new terms to 
be added to the Agreement . Any number 



of new terras on any subject could be 
added. The modifications discussed here 
were selected because they were 
considered at some time in the negotia- 
tions toward the present draft Agreement 
or they were considered in some other 
forum or context by both the Department 
and the Bureau as issues that might be 
settled by an agreement. 

U. S. Fish and Wildlife Service 
Proposal . Representatives of the U. S. 
Fish and Wildlife Service attended a 
Coordinated Operation Agreement 
negotiating session on July 14, 1982, to 
present the following draft article for 
the negotiators' consideration. 

Article Title: Coordination for Fish 
and Wildlife - Water Quality and 
Supply 

To the extent that they can be 
achieved with existing project 
facilities, the projects shall be 
operated to achieve the following 
goals : 

1. Restore and maintain populations of 
fish and wildlife on the average at 
pre-project levels; and 

2. Realize the projects' present and 
future potential for increasing 
these resources above pre-project 
levels consistent with other 
purposes of the projects. 

Any such cooperation requested or 
identified by a conservation agency 
that would require an unauthorized 
action by either water project should 
be brought to the attention of the 
Area Manager, U. S. Fish and Wildlife 
Service, the Director, California 
Department of Fish and Game, and if 
appropriate, the Regional Manager, 
National Marine Fisheries Service, 
with the aim towards seeking an 
authorized method to effect such 
cooperation. Descriptions of 
cooperative action and further 
guidance are specified in Exhibit A. 



25 



The "Exhibit A" referred Co in this 
draft article is not Exhibit A of the 
Agreement, but rather a proposed exhibit 
that the Fish and Wildlife Service 
intended to prepare. Fish and Wildlife 
Service representatives said this 
exhibit would give examples of how 
coordinated operations could benefit 
fish or wildlife in specific instances, 
such as when one project might be able 
to release water v*ien the other project 
was unable to provide water for instream 
use . 

The environmental consequences of the 
Department and Bureau agreeing on the 
Fish and Wildlife Service's proposed 
article are difficult to gauge. It 
states goals rather than specific 
actions, and the goals are somewhat 
unclear, especially as regards the 
definition of "pre-project levels". 

The apparent objective of the Fish and 
Wildlife Service's proposed article is 
to achieve higher fish and wildlife 
resource levels than presently exist and 
may exist in the future. To the extent 
that this goal might be achieved if the 
article were incorporated in the 
Agreement, the modification could have 
positive environmental effects as 
compared to the Agreement without the 
modification. The Fish and Wildlife 
Service proposal was not spelled out in 
enough detail to allow further 
analysis . 

Like the modified Delta standards alter- 
native, discussed ealier, the fish and 
wildlife service proposal would go 
beyond the underlying purpose and need 
and the objectives intended for the 
Proposed Action. 

Estuary Fish and Wildlife Agreement . In 
1974, the Department of Water Resources, 
the U. S. Bureau of Reclamation, the 
Department of Fish and Game, and the 
U. S. Fish and Wildlife Service signed a 
statement of intent to enter a 4-agency 
agreement for the management of fish and 
wildlife resources of the Sacramento-San 



Joaquin Delta prior to construction of 
the then-proposed Peripheral Canal. 
Such a 4-agency agreement was drafted, 
but not executed. The draft, however, 
was used as a basis for the fish and 
wildlife standards contained in Decision 
1485. Senate Bill 200 (1980), which was 
intended to authorize construction of 
the Peripheral Canal and other State 
water facilities, would also have 
required that the Department of Water 
Resources enter into a permanent agree- 
ment with the Department of Fish and 
Game. Senate Bill 200 was overturned in 
a statewide referendum. 

The scope of current negotiations toward 
a 2-agency agreement is limited to miti- 
gation for any adverse effects attribut- 
able to operation of four new pumps the 
Department of Water Resources plans to 
install at the Harvey 0. Banks Delta 
Pumping Plant. 

According to the environmental impact 
report for one draft of a 2-agency 
agreement, implementation of that 
agreement would have no significant 
adverse environmental impacts and would 
provide "equivalent or better protection 
for fish and wildlife resources than 
current Bay-Delta protective criteria 
established by Decision 1485" (and 
hence, the standards of Exhibit A) ll I . 
The same could probably be said about 
any other 2-agency agreement that the 
Department of Water Resources and the 
Department of Fish and Game might 
execute . 

Any attempt to merge an estuary fish and 
wildlife agreement with the proposed 
Coordinated Operation Agreement would 
have prolonged and complicated the 
already difficult negotiations. Also, 
this alternative would go beyond the 
underlying purpose, need, and objectives 
intended for the Proposed Action. It 
would address meeting obligations that 
do not now exist in lieu of defining the 
responsibilities of the CVP and SWP to 
meet existing obligations. 



26 



Modifications That 
Narrow the Scope 

This category represents modifications 
in which terms are subtracted from the 
Agreement . 

Proposed Agreement Without 
Article 10(h) . The proposed Agreement 
was originally submitted to the direc- 
tors of the Department and the Bureau in 
December 1982 as a draft. This 1982 
draft did not include a requirement, 
like the requirement in Article 10(h) of 
the current draft, that the parties 
negotiate a subsequent contract regard- 
ing SWP wheeling and purchase of CVP 
water. 

In such a subsequent contract , the capa- 
bilities of the CVP would be expanded by 
increasing the availability of wheeling 
services from the State Water Project. 
Correspondingly, the capabilities of the 
SWP would be expanded by acquiring the 
ability to purchase water supplies from 
the CVP. For both projects the result 
would be increased capability to export 
water from the Delta for an interim 
period. 

The direct impacts of water purchase 
and wheeling under such a subsequent 
contract would be more properly attrib- 
utable to that contract than to the 
Proposed Action, but such impacts could 
be considered cumulative impacts rela- 
tive to the Proposed Action. These 
impacts, as cumulative impacts, are 
discussed in the "Cumulative Impacts" 
section of Chapter 4. 

Impacts of implementing an agreement 
similar to that of the Proposed Action, 
but modified to eliminate Article 10(h), 
would be the same as impacts of the 
Proposed Action, except that cumulative 
impacts attributed to Article 10(h) in 
"Cumulative Impacts" would be absent. 



Alternative 4, 
No Coordination 

This alternative is not necessarily 
independent of the No Action alterna- 
tive, but it represents a different No 
Action scenario than that considered in 
the analysis of the No Action alterna- 
tive. The difference between No Coordi- 
nation, as will be discussed here, and 
No Action is that in the No Coordination 
alternative all the functions of a 
Coordinated Operation Agreement are 
absent. This means the CVP and the SWP 
do not coordinate operations and do not 
necessarily recognize the same Delta 
water quality standards at any time. In 
all No Action cases considered, the two 
projects are operated in a coordinated 
manner, and the only differences between 
the three No Action cases and between 
those cases and the Proposed Action are 
in regard to the Delta standards each 
project recognizes in critically dry 
years . 

In general, lack of communication or 
planned coordinated operation would 
cause probable inefficient use of water 
supplies and could threaten the 
protection of the Delta and the delivery 
capabilities of both projects. 

In 1983, the CVP and SWP operated 
without a coordination agreement, and no 
problems arose, but that is only because 
so much water was available in that 
very wet year that neither project had 
the physical capability to infringe on 
the other's water supplies or to deny 
the Delta water to meet its use and 
outflow requirements. In drier years, 
however, the No Coordination situation 
would be inefficient and confusing. It 
would also result in a court establish- 
ing the respective responsibilities of 
the Department and the Bureau concerning 
the Delta. This alternative was not 
considered realistic and, therefore, was 
not analyzed further. 



27 



Conceptual Comparison: 
Proposed Action versus No Action 

Since they represent the two options 
available to the parties, the Proposed 
Action and No Action were studied in 
more detail than the other alternatives. 
Table 2 illustrates the differences 
between the Proposed Action and the No 
Action alternatives as they were 
conceived and analyzed. 



CONCEPTUAL COMPARISON OF 
CRITICAL YEAR OPERATIONS, 
PROPOSED ACTION VERSUS NO ACTION 



Alternative 



Storage Export 

SWP CVP SWP CVP 



Required 

Delta 
Outflow 



Proposed Action 



No Action 
Case A 
Case B 
Case C 



+ 


+ 





G 





+ 











+ 


- 






EXPLANATION: 

= No Change from Proposed Action. 
+ = Increase from Proposed Action. 
= Decrease from Proposed Action. 

Case A -- CVP and SWP meet Tracy standards. 
Case B -- CVP meets Tracy standards; 

SWP releases its share of Exhibit A. 
Case C — CVP meets Tracy standards; 

SWP meets Exhibit A in full. 



In the table, the Proposed Action sets 
the conditions to v*iich the alternatives 
are compared. This is because the 
Proposed Action most nearly approximates 
continuation of the status quo. The 
State Water Project and the Central 
Valley Project have been operating to 
meet Delta standards equivalent to those 
of Exhibit A of the Coordinated Opera- 
tion Agreement since 1979. It should be 
noted, however, that no critical years 
have occurred since 1977. 



In No Action, Case A, Delta water qual- 
ity standards are reduced during periods 
of balanced water conditions in critical 
years; the Tracy standards replace the 
Exhibit A standards, allowing the two 
projects to retain more water in their 
reservoirs. In Case B, the increase in 
SWP reservoir storage observed in Case A 
is eliminated, as the SWP releases its 
share of the storage increase. Delta 
outflow is higher in Case B than in 
Case A, but still less than with the 
Proposed Action. Case C represents a 
more extreme case, in which the SWP 
guarantees the Delta outflow levels of 
the Proposed Action without CVP coopera- 
tion. To do this, the SWP must reduce 
its export pumping from the Delta as 
well as eliminate the reservoir storage 
increase observed in Case A. 

The conceptual scheme described in 
Table 2 may be unrealistic in regard to 
what the projects would do with any 
water saved by operating to Tracy 
standards rather than to Exhibit A 
standards. It is assumed that the 
entire saving is retained in reservoir 
storage. As an alternative to retention 
in storage, the projects could use the 
saving to deliver more water to their 
contractors, vAio in critical years would 
likely be receiving less than their 
noirmal water supplies. The same water 
saving might also be used to improve the 
quality of water exported from the 
Delta, in which case Delta outflow would 
increase (as compared to No Action, 
Case a) and water qualities in the Delta 
would improve generally. The assumption 
that the entire saving would be retained 
in storage was made because it describes 
the simplest case and is not implaus- 
ible; saving the water in the reservoirs 
strengthens the projects' insurance 
against continued drought. 

The differences between the Exhibit A 
standards and the Tracy standards are 
key to the analysis of alternatives, at 
least as far as the Delta is concerned. 
Table 3 compares flows and salinities 
that would be expected during balanced 



28 



water conditions in a critical year v*ien 
the Tracy standards are being met to the 
same year with the Exhibit A standards 
being met. In each instance, the 
comparison is made at the point in the 
Delta that would have the controlling 
standard. The controlling standard is 
the most demanding requirement in effect 



at a particular time. If the 
controlling standard is met, the other 
standards applicable at that time will 
also be met. At all times of the year, 
outflows are less and water qualities 
are worse under Tracy standards than 
they would be under the standards of 
Exhibit A. 











TAle 3 










COMPARISON OF SALINITIES A«) FLOWS AT CONTROLLING STATIONS IN CRITICAL YEARS 
EXHIBIT A VERSUS TRACY STANDARDS 




Period 


Controlling 
Exhibit A Station 

Rock Slough 


Exhibit A 
Standard 

1 50 ppm 


Associated 
Tracy Standard* 

31 5 ppm 


Difference 

+165 ppm 


Delta 


Outflow 


Exhibit A 

6,700 cfs 


Tracy Standard 

4,100 cfs 


January - 
March 


April 1 - 
April 15 


Chipps Island 
Rock Slough 




6,700 cfs 
150 ppm 


4,100 cfs 
31 5 ppm 


-2,600 cfs 
+1 65 ppm 


6,700 cfs 


4,100 cfs 


April 16 - 
April 30 


Rock Slough 




150 ppm 


315 ppm 


••■1 65 ppm 


6,700 cfs 


4,100 cfs 


May 1 - 
May 31 


Rock Slough 




150 ppm 


255 ppm 


+1 05 ppm 


4,900 cfs 


3,800 cfs 


June 1 - 


Jersey Point 




2.2 mmho 


2.9 mmho 


■tO.7 mmho 


4,000 cfs 


3,800 cfs 


August 15 
















August 16 
September 30 


Rock Slough 




250 ppm 


255 ppm 


+5 ppm 


4,100 cfs 


3,800 cfs 


October 1 - 
November 30 


Rock Slough 




250 ppm 


285 ppm 


+35 ppm 


4,700 cfs 


4,000 cfs 


December 1 - 
December 31 


Rock Slough 




250 ppm 


315 ppm 


+65 ppm 


5,500 cfs 


4,100 cfs 


» Salinity or flow projected at 
meet Tracy standards only (No 


the 
Act 


controlling 
ion, Case A) 


Exhibit A station, assuming CVP 


and SWP are 


operating to 


ppm = Chloride in parts per million. 

cfs = Delta outflow in cubic feet per second 

mmho = Electrical conductivity in millimhos^ 


Br centimeter. 








Source: Rich 


Kristof, U. S. Bureau 


of Reclamat 


ion, November 18, 


1983. 







29 



Operation Studies 

Environmental consequences of the 
Proposed Action and the No Action 
alternative were compared with the aid 
of computer simulations of project 
operations. Such simulations are 
commonly called operation studies. 
Operation studies require detailed sets 
of input data. Such data sets were 
available for the 1980 and 2020 levels 
of development. The "level of develop- 
ment" concept is related to demand for 
water, not with development of project 
facilities. 

In preparing this report, operation 
studies were performed for the 1980 
level of development, to approximately 
represent the present, and for the 2020 
level of development, which is consid- 
ered "ultimate" for planning purposes. 
In both sets of studies, only existing 
project facilities were recognized. The 
1980-level studies were based on 
observed historical hydrology for the 
period October 1921 through September 
1978. The 2020-level studies were based 
on observed and estimated hydrology for 
the period October 1894 through Septem- 
ber 1971. The differing periods were 
used because work on operation studies 
was split between the Department and the 
Bureau, and each agency has its own com- 
puter model. The Department performed 
the 1980-level studies, and the Bureau 
performed the 2020-level studies. 



Proposed Action 

Conditions indicated by the operation 
studies to exist if the proposed 
Coordinated Operation Agreement were 
executed and in effect are described 
below by comparison to the No Action 
cases . 



outflow during balanced water conditions 
would be reduced as compared to outflow 
under the Proposed Action. There would 
be a corresponding reduction in Delta 
water quality (increase in salinity). 
As an example. Figure 3 (derived from 
the 1980-level studies) compares pro- 
jected Delta outflow for calendar year 
1977. Figure 4 translates the outflow 
levels of Figure 3 into projected water 
qualities at Emmaton, on the Sacramento 
River, 

The reduction in Delta outflow would 
mean that the CVP and SWP would have 
more water at their disposal for 
purposes other than maintaining water 
quality in the Delta. Some or all of 
this increment in supply (as compared to 
the supply that would be available under 
the Proposed Action) could be delivered 
to project water users or, alterna- 
tively, could be retained in reservoir 
storage. If retained in storage, the 
water would serve as additional reserve 
against the possibility of continued 
drought. The amount of comparative 
increase in storage would depend on 
naturally occurring hydrology for the 
year or years in question. Continuing 
with the example based on 1977 hydrol- 
ogy, Figure 5 shows the projected 
storage increments the CVP and SWP would 
gain or retain by operating to the Tracy 
standards rather than those of 
Exhibit A. 

Retaining more water in storage would 
mean that at times less water would be 
released to rivers downstream from 
project reservoirs. Completing the 
example based on 1977 hydrology. 
Figures 6, 7, and 8 compare projected 
monthly flows with both projects meeting 
Exhibit A to monthly flows with both 
projects meeting the Tracy standards. 



No Action, Case A 

In this case, where during critical 
years both the CVP and SWP are operated 
only to meet the Tracy standards. Delta 



No Action Cases A, B, and C; 
Critical Period Analysis 

The capabilities of the CVP and SWP are 
usually measured by their performance 
through the "critical period", a series 



30 



FIGURE 3: PROJECTED DELTA OUTFLOW 

PROPOSED ACTION NO ACTION-CASE A 



10000 
90013 
8000 



- 250 




200 ^ 

CJ 



150 






2000 

1000 





_i 1 — •- 



100 



50 



LlJ 
Q 



JAN 



FEB ' MAR ' APR HAY ' JUN ' J UL AUG SEP OCT NOV DEC 

1977 HYDROLOGY 



-i0 



FIGURE 4: PROJECTED SALTS - SACTO R. AT EMMATON 



PROPOSED ACTION NO ACTION-CASE A 




JAN ' FEB ' MAR ' APR ' MAY ' JW ' JUL ' AUG ' SEP ' OCT ' NUV ■ uc^ 

1977 HYDROLOGY 



31 



FIGURE 5: STORAGE GAINED IN NO ACTION, 
CASE A (VS. PROPOSED ACTION) 



350 



250 



200 



CD 

S 150 
a 



01 



100 



50 




^ JAN FEB MAR APR MAY JUN JUL MX SEP XT NOV DEC 

1977 HYDROLOGY 



FIGURE 6: PROJECTED FLOW-SAC R. AT CHICO LANDING 




PROPOSED ACTION NO ACTION-CASE A 










14000 
12000 


/ 




10000 


/ 




\2. 6000 

CJ 

O 6000 


^^v Y ^Sx 4r 




4000 


- 




2000 






B 


JAN FEB MAR APR MAY JUN JUL AUG SEP OCT NOV DEC 




1977 HYDROLOGY 



32 



FIGURE 7: PROJECTED FLOW-FEATHER R. AT THERMALITO 

PROPOSED ACTION NO ACTION-CASE A 



10000 




3000 
2000 
1000 - 




"JAN ' FEB ' MAR ' APR MAY JUN ' JUL ' AUG ' SEP ' oa ' NOV ' DEC 

1977 HYDROLOGY 



FIGURE 8: PROJECTED FLOW-AMERICAN R. BELOW NIMBUS 



1000 



300 
200 
100 - 




PROPOSED ACTION NO ACTION-CASE A 





—1 1— 



JAN FEB MAR APR MAY JUN JUL AUG 

1977 HYDROLOGY 



SEP OCT NOV DEC 



33 



of dry and critical years spanning 1928- 
1934, The natural hydrology observed 
during this period is assumed to recur, 
and operation of CVP and SWP facilities, 
along with other factors affecting the 
disposition of water supplies, are 
superimposed on it. This technique was 
used to compute the CVP and SWP water 
supplies for Exhibits B-1 and B-2 of the 
proposed Agreement. 

Operation study results (1980-level) 
comparing the Proposed Action to the 
three cases of the No Action alternative 
through the critical period are 
presented in Table 4 (compare to 
Table 2). The study was based on the 
period March 1928 through February 1935, 
with each of the 12-month periods 
beginning with March 1931 assumed as 
critical years in which the CVP, the 
SWP, or both would operate for Tracy 
standards in the absence of the 
Coordinated Operation Agreement (that 
is, in the No Action alternative). 

The study showed that with both projects 
operating for Tracy standards in the 
critical years (No Action, Case A), the 
Delta outflow requirements of Exhibit A 
would be shorted by 2,273,000 acre-feet 
over the period. As a result, the 
projects would be able to retain 
1,905,000 acre-feet more water in 
reservoir storage. 

If the SWP were to continue operating as 
if Exhibit A standards controlled in the 
Delta v*iile the CVP operated for Tracy 
standards (No Action, Case B) , about 
half of the deficiency in outflow needed 
to meet Exhibit A would be made up, and 
all of the increment in residual SWP 
storage observed in Case A would be 
eliminated . 

Operating the SWP to meet Exhibit A 
requirements in full while the CVP was 
operating to meet Tracy standards only 
(No Action, Case C) would cost the SWP 
water users 983,000 acre-feet of their 
SWP supply over the period. If, under 
this scenario, the SWP were operated in 
all years in a manner that anticipates 



T^le 4 

DISPOSITION OF WATEK IN 7-YEAR CRITICAL PERIOD, 

1?28 TO 1935 

PROPOSED ACTION VERSUS NO ACTION* 

(Increase or Decreaae from Proposed Action, 

in Thousand Acre-Feet) 













Reqtiired 




Stor 


ago 


Export 


Delta 


Alternative 


SWP 




CVP 




SWP 




CVP 




Outflow 


Proposed Action 





No Action 












Case A 


+1,118 


+717 








-2,273 


Case B 





+717 








-1,071 


Case C 


Q 


-^79 


-983 ♦♦ 









EXPLANATION: 

Case A — CVP and SWP meet Tracy standards. 
Case B — CVP meets Tracy standards; 

9^P releases its share of Exhibit A. 
Case C — CVP meets Tracy standards; 

SWP meets Exhibit A in full. 

♦ Based on 1980-level operation studies. 

♦• About 143,000 acre-feet on a firm annual yield 
basis. This value includes adjustments for 
carriage water releases, unregulated flovo, and 
stored supplies. 



the possibility of a critical year in 
which the CVP would honor Tracy stan- 
dards only, firm annual water supply 
deliveries by the SWP to its contractors 
would have to be cut by about 143,000 
acre-feet . 



Environmental Comparison 
of Alternatives 

(Proposed Action vs. No Action) 

In general, from an environmental point 
of view, the Proposed Action would help 
to protect the Delta and existing water 
uses there; however, operation of CVP 
facilities to meet the Delta standards 
of the Proposed Action's Exhibit A in 
critically dry years could exacerbate a 
problem of river temperatures sometimes 
being too warm for successful spawning 
and rearing of salmon, particularly in 
the upper Sacramento and Trinity 
rivers . 



34 



The most environmentally significant aim 
of the Proposed Action is to commit both 
the SWP and CVP to meeting the Exhibit A 
Delta standards of the Agreement. This 
commitment would be undertaken by both 
the Bureau and the Department to protect 
the Delta environment. Available 
information indicates that the Exhibit A 
standards would indeed be more effective 
in protecting the Delta than would the 
alternative Tracy standards in critical 
years. In other years, the Delta would 
receive protection equal to that of the 
Exhibit A standards with or without the 
Proposed Action. That the Exhibit A 
standards would be more protective in 
critical years should not be surprising, 
because the Exhibit A standards are the 
same (at least as far as the Delta is 
concerned) as the Decision 1485 stand- 
ards of the State Water Resources 
Control Board. 

The greater protection afforded to the 
Delta by the Exhibit A standards of the 
Proposed Action would be observable 
(during critical years) in: 

° Significantly better water quality at 
the Rock Slough intake of the Contra 
Costa Canal. This would help to 
assure that poor water quality would 
not impair industrial production. It 
would also help to assure adequate 
quality for municipal water users in 
eastern Contra Costa County. 

" Significantly better water quality for 
agriculture in the western Delta. 

' Water qualities suitable for striped 
bass spawning in the lower San Joaquin 
River, **iere up to 45 percent of the 
striped bass population of the Delta- 
Bay estuary spawns. 

° Ample Delta outflow to maintain an 
entrapment zone favorable to growth 
and survival of young striped bass. 

° Reduced diversion of striped bass eggs 
and larvae, and of young salmon, when 
pumping restrictions are in effect 
during May, June, and July (compared 
to unrestricted pumping). 



The Exhibit A standards would also 
provide better quality water to Suisun 
Marsh than would be provided in critical 
years with the Tracy standards control- 
ling. The better quality of water would 
have a significant favorable effect on 
natural production of waterfowl food in 
the marsh. 

The greater protection afforded to the 
Delta and Suisun Marsh by the Exhibit A 
standards would be provided by releasing 
more water from project reservoirs for 
Delta use and outflow. Such releases, 
combined with releases for all other 
demands and purposes, could draw down 
water levels in the reservoirs during 
dry periods. Whether reservoir levels 
with the Exhibit A standards being met 
during critical years would be any lower 
than they would be with some less 
demanding Delta standards being met, 
such as the Tracy standards, depends on 
what the project operators would do with 
the water they could save by meeting the 
less demanding Delta standards. If they 
kept the water in the reservoirs, the 
reservoirs would be maintained at higher 
levels. Higher water levels in the 
CVP's Shasta, Clair Engle, and Folsom 
lakes would mean cooler water could be 
released to the Sacramento, Trinity, and 
American rivers downstream from these 
reservoirs. The cooler water in criti- 
cal years would significantly improve 
conditions for spawning and rearing of 
Chinook salmon, a fish species of high 
sport and commercial value. Thus, it is 
an adverse impact of the Proposed Action 
that a project capability to provide 
water temperatures cool enough for 
successful salmon spawning and rearing 
would be lessened by the Bureau's 
commitment to meet the Exhibit A Delta 
standards in all years. However, based 
on operation studies covering 83 years 
of record (1895-1977), this adverse 
impact would occur in only about 3 years 
out of 83, which is a frequency of 
occurrence of less than 4 percent. 

Another possible adverse impact of the 
Proposed Action, as compared to No 
Action, could occur in San Francisco 
Bay. Delta outflow surges in critical 



35 



years (if any) and in the years 
immediately following critical years 
could be smaller or less numerous with 
the Proposed Action, because the proj- 
ects would have more capacity available 
for storing runoff from major storms. 
The operation studies used to compare 
Proposed Action to No Action give only 
monthly flows and are therefore not 
usable for differentiating among alter- 
natives in regard to outflow surges. If 
differences in surges could be identi- 
fied, they would be small and infrequent 
(historically, 3 in 83 years). It 
should be recognized that such differ- 
ences may not occur at all under 
different operating assumptions. Most 
important, it is judged more beneficial 
to the estuary in the long term to meet 
these standards than not to meet them. 

In No Action, Case A, in vhich both the 
CVP and SWP are operated to meet the 
Tracy standards in critical years, a 
lesser degree of protection would be 
afforded to the Delta. This lesser 
degree of protection would be observable 
in: 

Lower water quality at the Rock Slough 
Intake of the Contra Costa Canal. The 
maximum of 500 ppm TDS recommended by 
the Environmental Protection Agency 
for drinking water would sometimes be 
exceeded, as would the EPA-reconinended 
maximum of 250 ppm chloride. Industry 
in eastern Contra Costa County would 
be adversely affected by chloride in 
excess of 150 ppm that would persist 
longer than with the Proposed Action. 

Lower water quality for agriculture in 
the western Delta. Crop yield 
declines (compared to yields obtain- 
able with the Exhibit A standards) 
would be expected. 

Salinity levels in the lower San 
Joaquin River above the levels at 
which striped bass prefer to spawn. 

Delta outflows insufficient to main- 
tain an entrapment zone in the Suisun 
Bay area. Resulting decreases in 



Neomysis and young striped bass 
abundance would be expected. 

° A possibility for increased reverse 
flow in the lower San Joaquin River, 
drawing more fish into the export 
pumps . 

Reduced spring flows in the Sacramento 
River, adversely affecting out-migrant 
juvenile salmon. 

All of the adverse effects in the Delta 
observed in No Action, Case A, would be 
eliminated in No Action, Case C, v^ere 
the SWP cuts exports to assure mainte- 
nance of Exhibit A and Decision 1485 
standards. However, each year the SWP 
would lose about 140,000 acre-feet of 
yield worth over $28 million, based on 
least-cost alternative sources. In No 
Action, Case B, all effects in the Delta 
would be intermediate between the 
Proposed Action and No Action, Case A. 

In all the No Action cases, temperatures 
for salmon spawning and rearing in the 
Sacramento, Trinity, and American Rivers 
could (but not necessarily would) be 
maintained at more favorable tempera- 
tures than could be maintained with the 
Proposed Action in critically dry years. 
Also, water in Shasta, Clair Engle, and 
Folsom lakes could be maintained at 
higher levels, which would be good for 
resident fish and reservoir recreation. 
This water level effect would be 
observed at the SWP's Lake Oroville only 
in No Action, Case A. 

As stated above, the analysis of the No 
Action alternative was based on opera- 
tion studies in which it was assumed 
that any water that either project might 
save by meeting only the Tracy standards 
in the Delta rather than the Exhibit A 
standards would be retained in the 
reservoirs . 

If the projects delivered water to their 
contractors in lieu of retaining it in 
storage, the environmental differences 
between the Proposed Action and No 
Action would be eliminated vhere rivers 



36 



and reservoirs are concerned. Thus, the 
same temperature control problems in the 
rivers below major CVP reservoirs that 
were described for the Proposed Action 
would also exist in No Action. In the 
Delta, the environmental differences 
between Proposed Action and No Action 
would be as great or greater if the 
project operators delivered any water 
they could save by meeting only the 
Tracy standards, because more water 
could be exported. Increased exports 
would exacerbate all the environmental 
problems, such as reverse flows and fish 
entrainment, that are associated with 
project exports. Thus, the environ- 
mental drawbacks described for the No 
Action alternative in the Delta could be 
made worse . 

To determine how much more water CVP and 
SWP contractors could get if the differ- 
ence between the Tracy and Exhibit A 
standards were delivered rather than 
retained in storage, estimates were 
based on the numbers in Table 4. If 
both projects operated in a manner that 
assumed realization of the No Action 
Case A scenario in critical years, firm 
annual yield increases of about 130,000 
acre-feet for the CVP and about 200,000 
acre-feet for the SWP could be achieved. 
Such increases could be of significant 
economic benefit to the contractors of 
both projects. 



Preferred Alternative 

Relative advantages and disadvantages of 
alternatives are summarized in Table 5. 

Alternative 1, the Proposed Action, is 
the alternative preferred by the U. S. 
Bureau of Reclamation and the Department 
of Water Resources. This alternative is 
preferred because: 

It is an available and implementable 
option. 



It would resolve issues between the 
State and Federal Governments concern- 
ing the respective water supplies of 
the State Water Project and Central 
Valley Project, 

It would facilitate efficient opera- 
tion of the two water projects. 

It would afford protection to the 
water-related environment in the 
Delta. 

It would provide a basis for orderly 
planning and continuing development of 
the two projects. 

No alternative to the Proposed Action, 
other than No Action, represents an 
available and implementable option. No 
Action has potential to have certain 
environmental advantages over the 
Proposed Action because the CVP water 
that would be committed to use in 
meeting the Delta standards in critical 
years with the Proposed Action would 
remain uncommitted and therefore poten- 
tially available to help control river 
temperatures below CVP reservoirs. 
However, in No Action, there is no 
assurance that the uncommitted water 
would be used to help control river 
temperatures . 

Executing this draft Coordinated Opera- 
tion Agreement of the Proposed Action 
would not eliminate the possibilities to 
obtain agreement on matters that go 
beyond its scope. 



Mitigation Measures 

The Agreement provides overall resource 
level protection. The Exhibit A 
standards of the Proposed Action are 
mitigation themselves for the projects. 
There is no proposed mitigation for the 
Proposed Action beyond the Exhibit A 
standards . 



37 



RELATIVE ADVANTAGES AND DISADVANTAGES OF REASONABLE ALTERNATIVES 



Alternatives 



Proposed Action 
(Compared to No Action) 



Advantages 



Better overall protection for 
migratory fish in the Delta during 
critically dry years. 

Higher potential agricultural produc- 
tivity in the western Delta during 
critically dry years. 

Higher productivity of waterfowl food 
in Suisin Marsh during critically dry 
years. 

Higher water quality for MM use in 
the Delta during critically dry 
years. 



Diaad vantages* 



Potential for increased drawdovn at 
CVP reservoirs during critically dry 
years, with minor adverse effects on 
esthetics and recreation. 

Potential^ local adverse effects on 
salmon spawning and rcarirq due to 
high river temperatures during late 
summer and fall months of critically 
dry years. 

Potential for slightly reduced Delta 
outflow peaks in the year or years 
immediately followifig critically dry 
years. 



No Action, Case A ♦* 
(Compared to Proposed Action) 



Retains existing CVP option to reserve 
portion of water stored in reservoirs 
for maintaining river temperatures 
suitable for salmon spavning in late 
summer and fall of critically dry 
years . 

Disadvantages of Proposed Action 
avoided if water saved by meeting less 
demanding Delta standards is retained 
in storage. 



Advantages of Proposed Action 
foregone. 



No Action, Case B ♦* 
(Compared to Proposed Action) 



Same as Case A 



Advantages of Proposed Action fore- 
gone, but to a lesser degree than in 
Case A. 



No Action, Case C ** 
(Compared to Proposed Action) 



Modified Agreement 

(Compared to Proposed Action) 



No Coordination 

(Compared to Proposed Action) 



Same as Proposed Action 



Firm water supply yield of SWP 
reduced by 143,000 acre- feet. 



Potential for increased flexibility. 



Modifications were not found to be 
acceptable to the reasoning and 
trial and error negotiations. 



None 



Decrease in environmental protection 
arel in reliability of project yields. 



* Nb impacts were judged to be significant based on CEQA criteria listed in Appendix K. 
••Case A = CVP and SWP meet Tracy standards. 

Case B : CVP meets Tracy standards; SWP releases its share of Exhibit A. 

Case C : CVP meets Tracy standards; SWP meets Exhibit A in full. 



38 



Chapter 4. AFFECTED ENVIRONMENT AND ENVIRONMENTAL CONSEQUENCES 



The affected environment, where environ- 
mental consequences attributable in some 
way to the proposed Coordinated Opera- 
tion Agreement might occur, includes the 
river systems and reservoirs where proj- 
ect water supplies originate; the Delta, 
where the affected waters mingle ; and 
the service areas, where project water 
is used. Potential consequences in each 
of these areas are discussed in this 
chapter with respect to the Proposed 
Action and No Action. As discussed in 
Chapter 3, there are three possible 
cases for the No Action alternative. 
Each case will be evaluated separately 
except when there are no differences in 
impacts. Environmental consequences 
were considered as the differences — 
especially any adverse differences — 
between the environmental conditions 
that would be expected to exist under 
these two alternatives. 

As discussed in Chapter 3, the two 
projects could and might be operated in 
the same way whether the Proposed Action 
is taken or not. With no differences in 
operations, there would be no differ- 
ences in environmental conditions. 
However, in critical years the projects 
could be operated differently in No 
Action than they would be in the 
Proposed Action. The environmental 
analysis of Proposed Action versus No 
Action in this chapter is based on 
operation studies designed to bring out 
potential environmental differences 
between the Proposed Action and No 
Action. For a discussion of the 
operation studies, see Chapter 3. 



Regional Setting 

The Proposed Action and No Action are 
considered within the context of the 
State of California, the Central Valley 
basin, and the two largest water devel- 
opment projects in that basin: the 



Central Valley Project (CVP) and the 
State Water Project (SWP). 



Central Valley Basin 

The proposed Agreement deals with the 
management of riverflows in the Central 
Valley basin of California and with the 
distribution of water supplies in the 
basin and from the basin by the Central 
Valley Project and the State Water 
Project . 

The Central Valley basin comprises the 
450-mile-long Central Valley and the 
surrounding upland and mountain areas 
draining into it. The area encompasses 
some 60,000 square miles, or about 
40 percent of California. The valley 
portion, generally flat below an eleva- 
tion of 400 feet, is an alluvial plain 
varying from 40 to 60 miles in width. 
It has been developed extensively for 
agriculture. The climate is hot in 
summer and mild in winter. This, 
combined with the deep alluvial soils, 
allows high farm productivity, but 
irrigation is required. 

The northern half of the Central Valley, 
the Sacramento Valley, is drained by 
California's largest river system, the 
Sacramento. Major tributaries include 
the McCloud, Pit, Yuba, Feather, and 
American rivers. 

The southern half of the Central Valley, 
the San Joaquin Valley, has two sub- 
basins. The northern part drains via 
the San Joaquin River ; the southern 
part, called the Tulare Lake basin, 
drains internally except in rare 
instances vAien floodwaters overtop a low 
divide and flow into the drainage of the 
San Joaquin River. Major tributaries to 
the San Joaquin include the Merced, 
Tuolumne, and Stanislaus rivers. 



39 



Precipitation on the Central Valley 
basin is heavier in the more northerly 
areas and falls mostly from November 
through April. Except for thunderstorms 
in the mountain areas, summers are 
usually almost rainless throughout the 
region. Annual rainfall averages more 
than 10 inches everywhere in the Sacra- 
mento Valley, and rain or snowfall on 
surrounding mountains averages more than 
60 inches annually over large areas. 
Averages are lower in the San Joaquin 
Valley and its surrounding mountains. 
Precipitation varies widely, however, 
from year to year, so average years are 
rare. Because a significant portion of 
precipitation in the basin occurs as 
winter snowfall in the mountains, runoff 
may lag precipitation, and the season of 
runoff often extends into late spring 
and summer as the winter snows melt. 

Flood control and/or water storage works 
exist on all major streams in the basin, 
which alters the natural flow patterns. 
These facilities, including facilities 
of the CVP, SWP, Metch Hetchy, and 
Mokelumne River Aqueduct Project, save 
water for the dry season and protect 
lives and property against the winter 
floods that were common before water 
development. They also produce hydro- 
electric power, enhance recreation 
opportunities, and serve other 
purposes , 

The area in the center of the Central 
Valley basin where the Sacramento and 
San Joaquin valleys merge coincides with 
a break in the coastal mountains border- 
ing the basin on the west side. Here 
the Sacramento River, the much smaller 
San Joaquin River, and other streams 
meet in the Sacramento-San Joaquin Delta 
before flowing on toward the Pacific 
Ocean. This delta, unlike most river 
deltas, is wide landward and narrow 
seaward. It forms the upstream portion 
of an estuary that includes Suisun Bay, 
San Pablo Bay, and San Francisco Bay 
(see Affected Environment, Delta-Bay 
Estuary) . 



The CVP and SWP 

The Central Valley Project, operated by 
the U. S. Bureau of Reclamation, extends 
the full length of the Central Valley 
basin. It has been developed from the 
1930s through the present. The project 
supplies irrigation water, provides 
flood control, improves navigation, 
supplies domestic and industrial water, 
generates hydroelectric power, conserves 
fish and wildlife resources, provides 
recreational opportunities, and protects 
water quality. The CVP stores and 
develops surplus water supplies of the 
Sacramento, American, and Trinity rivers 
for use in the Sacramento River basin as 
well as the water-deficient lands in the 
San Joaquin Valley. 

Lake Shasta on the Sacramento River and 
Folsom Lake on the American hold back 
runoff from winter storms and release it 
through the dry season to maintain 
riverflows higher than they would be 
under natural conditions. Clair Engle 
Lake likewise holds back winter runoff, 
but riverflows are usually significantly 
less than they would be under natural 
conditions. The Trinity River drainage 
is outside the Central Valley basin, but 
water from the Trinity is brought into 
the Sacramento River drainage through 
the Clear Creek Tunnel. 

The CVP-controlled Sacramento River, 
augmented by water from the Trinity, 
supplies irrigated areas in the Sacra- 
mento Valley. At Sacramento, flows of 
the Sacramento River are augmented by 
flows entering from the CVP-controlled 
American River. A few miles downstream, 
the river enters the northern part of 
the Sacramento-San Joaquin Delta. 

Some of the water entering the Delta 
takes a direct course toward Suisun Bay, 
and some finds its way into the interior 
Delta through the CVP ' s Delta Cross 
Channel and natural channels. Thus, 
releases from CVP reservoirs augment the 
supply of fresh water in the Delta 
during the drier times of the year. 



40 



Among the diverters of the fresh water 
available in the Delta is the CVP, which 
pumps water from the southern Delta at 
its Rock Slough and Tracy pumping 
plants. The Rock Slough pumping plant 
serves the Contra Costa Canal, providing 
water mainly to municipal and industrial 
users in parts of Contra Costa County. 
The Tracy Pumping Plant serves the 
Delta-Mendota Canal, which conveys water 
to agricultural users in the San Joaquin 
Valley and to facilities of the CVP ' s 
San Luis Unit. Some of the water 
provided in the San Joaquin Valley is 
delivered on an exchange basis to areas 
that used water from the San Joaquin 
River before construction of the CVP. 

Flows of the San Joaquin River are 
controlled and stored by the CVP's 
Friant Dam and Millerton Lake. These 
facilities, in foothills above Fresno, 
allow diversion of a major portion of 
the flows of the San Joaquin River into 
the Friant-Kern Canal, a CVP facility 
that conveys water along the eastern 
periphery of the Tulare Lake basin to 
agricultural areas as far south as 
Bakersfield. A lesser portion is 
diverted into the Madera Canal, v^iich 
serves certain areas in the San Joaquin 
Valley. 

The CVP's San Luis Unit shares San Luis 
Reservoir and the San Luis Canal with 
the State Water Project. The reservoir 
stores excess flows pumped from the 
Delta in the winter and spring, and the 
San Luis Canal delivers water from the 
reservoir and the Delta-Mendota Canal to 
agricultural areas along the west side 
of the San Joaquin Valley in the Tulare 
Lake basin and in the region of transi- 
tion between that landlocked basin and 
the drainage of the San Joaquin River. 

The existing facilities of the Central 
Valley Project provide full, supplemen- 
tal, or temporary water supply to about 
3 million irrigable acres. They also 
provide 154,000 acre-feet of water for 
municipal and industrial use and 
generate over 3.5 billion kilowatt-hours 
of electricity annually in addition to 



supplying the energy needs of project 
facilities . 

The State Water Project, built and 
operated by the Department of Water 
Resources, is similar in some ways to 
the Central Valley Project. Both 
projects store runoff in the Sacramento 
Valley basin, release stored water to 
the Sacramento River and the Delta, and 
pump water out of the southern Delta for 
delivery to water users to the south and 
west. The State Water Project's storage 
facilities are on the Feather River, and 
its facilities for distributing water 
from the Delta extend farther south than 
those of the CVP. 

The uppermost facilities of the SWP are 
three small lakes — Davis, Frenchman, 
and Antelope — located high on separate 
forks of the Feather River. The forks 
meet at Oroville Reservoir, the 
project's principal storage facility. 
Water released from Oroville is used to 
generate electrical power in the Hyatt- 
Thermal ito complex just downstream. 
Below the Thermalito Afterbay outlet, 
releases continue down the Feather 
River, which joins the Sacramento River 
21 river miles above Sacramento. Here 
waters managed by the SWP mingle with 
and become indistinguishable from the 
waters of the CVP. Water from the two 
projects flows commingled into the 
Delta. 

In the southern Delta, the SWP operates 
Harvey 0. Banks Delta Pumping Plant and 
Clifton Court Forebay. The forebay 
takes in Delta water as the high tide 
recedes; then its gates are closed, and 
the pumping plant pumps from the fore- 
bay. The pumps lift the water to the 
beginning of the 444-mile California 
Aqueduct and to another pumping plant at 
the beginning of the South Bay Aqueduct, 
which serves the southern San Francisco 
Bay area. The California Aqueduct 
continues along the west side of the San 
Joaquin Valley to the Federal-State San 
Luis Reservoir, and then along the west 
side of the southern San Joaquin Valley 
in the Tulare Lake basin, v*iere most of 



41 



the SWP's agricultural water customers 
are located. 

Leaving the Central Valley basin, the 
California Aqueduct rises 2,700 feet in 
a series of pump lifts to climb over the 
Tehachapi Mountains. On the other side, 
the aqueduct splits into a long East 
Branch and a shorter West Branch, both 
of which take SWP water to the project's 
predominantly urban customers in parts 
of Southern California. 

Some ways in which the CVP and SWP 
differ include the ratio of urban to 
agricultural water users served by each 
project and the yields and storage 
capacities of the projects. Of the 
water now being delivered by the CVP, 
95 percent goes to agricultural users. 
SWP water goes about equally to 
agricultural and urban use. Based on 
Exhibit B-2 of the proposed Coordinated 
Operation Agreement, the CVP's yield 
(water supply available to the project 
on a reliable basis) is nearly 100 per- 
cent higher than the SWP's if water 
deliverable both upstream from the Delta 
and as export from the Delta is counted, 
and 44 percent higher if only water 
deliverable as export is counted. The 
difference in yields derives partly from 
a difference in upstream storage 
capacities: the CVP's storage capacity 
in Clair Engle, Shasta, and Folsom 
Reservoirs totals 8 million acre-feet, 
while the capacity of the SWP's single 
significant upstream storage facility at 
Oroville is 3.5 million acre-feet. Due 
to its lesser upstream storage, the SWP 
relies more than the CVP on exporting 
surplus unstored flows available in the 
Delta during winter and spring. 

Another significant difference between 
the two projects lies in their 
respective capacities for export from 
the Delta. The CVP can pump a maximum 
of 4,600 cubic feet per second (cfs) 
into the Delta-Mendota Canal. Adding 
the Contra Costa Canal brings CVP export 
capacity to 4,950 cfs. The SWP can pump 
6,400 cfs at the Banks Pumping Plant. 
With its greater export capacity, the 



SWP is in a better position to take 
advantage of surplus flows when they are 
available in the Delta. Even so, the 
SWP will have to construct additional 
facilities, both in the Delta and 
elsewhere, to satisfy obligations coming 
due under existing contracts. 



Affected Environment 



Delta-Bay Estuary 

The Delta-Bay estuary (Figures 9 and 10) 
is the Delta of the Sacramento and San 
Joaquin rivers plus Suisun and San 
Francisco bays. The estuary connects 
its two principal tributary rivers and 
the Calaveras, Mokelumne, and Cosuranes 
rivers to the Pacific Ocean. These 
rivers drain the Central Valley basin. 



Hydrology and Water Use 

Some of the water reaching the Delta is 
used there and some is withdrawn for 
use elsewhere (exported). What remains 
flows into Suisun Bay, then into San 
Francisco Bay (including San Pablo Bay), 
and then to the ocean. The latter parts 
of this sequence may exist more in logic 
than in observable reality most of the 
time, because tidal influences tend to 
overwhelm fresh water flows once they 
get beyond the Delta, Summer and fall 
Delta outflows generally range between 
5,000 and 10,000 cubic feet per second 
(cfs), while the tides at the western 
boundary of the Delta flow at a rate of 
200,000 cfs. 

On the average, about 21 million 
acre-feet of water reaches the Delta 
annually, but actual inflow varies 
widely from year to year and within the 
year. In 1977, a year of extraordinary 
drought. Delta inflow totaled only 
5.9 million acre-feet; while inflow for 
1983, an exceptionally wet year, was 
about 70 million acre-feet. On a sea- 
sonal basis, average natural flow to the 
Delta varies by a factor of more than 10 
between the highest month in winter or 
spring and the lowest month in fall. 



42 




Figure 9. SAN FRANCISCO BAY COMPLEX. 



43 



LEGEND 

1 - SUISUN BAY 

2 - SUISUN MARSH 

3 - CHIPPS ISLAND 

4 - EMMATON 

5 - JERSEY POINT 

6 - H.O.B. DELTA PUMPING PLANT 

7 - TRACY PUMPING PLANT 

8 - CLIFTON COURT FOREBAY 

9 - CALAVERAS RIVER 

10 - PRISONERS POINT 

11 - SAN ANDREAS 

12 - TERMINOUS 

13 - MOKELUMNE RIVER 

14 - COSUMNES RIVER 

15 - CITY OF VALLEJO INTAKE 




FIGURE 10: SACRAMENTO - SAN JOAQUIN DELTA 



44 



Water from the Delta supplies farms and 
cities in the local area, and the CVP 
and SWP rely on the Delta for water they 
provide to service areas comprising 
one-third of the land area of California 
and two-thirds of its population. 

If a year of average inflow should occur 
in the mid-1980s, about 10 percent of 
the water reaching the Delta would be 
withdrawn for local use, 30 percent 
would be withdrawn for export by the two 
projects, 20 percent would be needed for 
salinity control, and' the remaining 
40 percent would become Delta outflow in 
excess of minimum requirements. The 
excess outflow would occur almost 
entirely during the season of high 
inflow. 

Salinity control is necessary because 
the Delta is contiguous with the ocean, 
and its channels are at or below sea 
level. Unless repelled by continuous 
seaward flow of fresh water, sea water 
will advance up the estuary into the 
Delta and degrade water quality. During 
winter and early spring, flows through 
the Delta are usually above the minimum 
required to control salinity (the situa- 
tion described as "excess water condi- 
tions" in Chapter 2); but at least for a 
few months in summer and fall of most 
years, salinity must be carefully moni- 
tored and controlled ("balanced water 
conditions" as described in Chapter 2). 

The monitoring and control is provided 
by the CVP and SWP and regulated by the 
State Water Resources Control Board 
(State Board) under its water rights 
authority. Coordination of CVP and SWP 
salinity monitoring and control func- 
tions has been arranged on an annual 
basis in the past and would be accom- 
plished for the long term by the pro- 
posed Coordinated Operation Agreement. 



Protective Standards 

The State Board promulgates water 
quality and outflow standards for the 
Delta-Bay estuary. Its current 



standards are contained in Water Right 
Decision 1485 (1978). That decision 
orders the Central Valley Project and 
State Water Project to operate their 
facilities so as to guarantee certain 
conditions, most of which were described 
in terms of electrical conductivity or 
chloride (both measures of salinity). 
Separate categories of standards were 
specified to protect agriculture, 
municipal and industrial use, and fish 
and wildlife. 

In Decision 1485, the State Board 
declared: 

"The underlying principle of these 
standards is that water quality in the 
Delta should be at least as good as 
those levels which would have been 
available had the state and federal 
projects not been constructed, as 
limited by the constitutional mandate 
of reasonable use." 

In applying this principle, the State 
Board considered as its mandates: 

Protection of vested water rights. 
Protection of the public interest. 

According to the State Board, the 
decision that resulted, 

"... deals with a limited resource 
and involves essentially the 
allocation of water shortages", and 
" ... provides a reasonable level of 
protection to all uses of Delta 
supplies, recognizing the severe 
consequences if upstream supplies are 
exhausted ." 

The water quality and flow standards 
included in the proposed Coordinated 
Operation Agreement as Exhibit A are the 
same as those of Decision 1485 except 
that certain standards for Suisun Marsh, 
on the north side of Suisun Bay, are 
omitted. The omitted standards became 
effective on October 1, 1984. These 
standards were discussed under "Modified 
Agreement" in Chapter 3. 



45 



Freshwater outflow from the Delta to San 
Francisco Bay is believed to be impor- 
tant to maintaining desired environ- 
mental conditions in the bay, but no 
standards govern such outflow. High 
volume, uncontrolled outflow surges 
during the winter cause fresh water to 
penetrate well into the central bay, 
from which it can enter the southern bay 
by tidal exchange. Such events cause 
salinity stratification in much of the 
South Bay that can persist for several 
weeks or months following the initial 
appearance of fresh water. 

In Decision 1485, the State Water 
Resources Control Board emphasized that 
consideration must be given to the 
outflow needs of the bay and directed 
that studies to investigate these 
outflow needs be initiated by October 
1979. The studies are in progress, and 
their results will be considered when 
the State Board reviews Decision 1485. 
In the meantime, the Board has offered 
an interim policy guideline that calls 
for Delta outflow surges of at least 
10,000 cubic feet per second for 5- to 
10-day intervals about four times a year 
in most years and at least once a year 
during drier periods. 



Delta Agriculture 

The Delta, a 700,000-acre region of 
low-lying land and waterways at the 
landward end of the estuary, is mainly 
farmland. Prior to development, v^ich 
began in the mid-19th century, the Delta 
was mainly tule marsh and grassland, 
with some high spots rising to a maximum 
of about 10 to 15 feet above mean sea 
level. Settlers soon discovered that 
tracts of Delta land could be 
productively farmed if dikes were built 
to protect them from tidal inundation. 
Crops grew well in the deep peat soils 
left by thousands of years of tule 
growth and decay. 

Gradually, through the latter half of 
the 19th century and the early part of 
the 20th, the low dikes of the early 



Delta farmers became a system of levees 
that now protect about 510,000 acres of 
farmland on 60 major islands and tracts. 
There are now about 1,100 miles of 
levees, some standing 2 5 feet high and 
reaching 200 feet across at the base 
/8/. 

Behind the levees, peat soils have 
subsided over the years due to complex 
and interrelated factors, including 
oxidation, shrinkage, and soil loss by 
wind erosion. As a result, some of the 
island surfaces now lie more than 
20 feet below mean sea level and as much 
as 30 feet below high-tide water levels 
in surrounding channels. This puts much 
of the Delta under an unrelenting threat 
of inundation, especially since many 
Delta levees are structurally unstable. 

All of the major tracts and islands have 
been flooded at least once since their 
original reclamation, and a few have 
been allowed to remain flooded. Delta 
lands in the areas of deep peat soil, 
where subsidence has been greatest, are 
expensive both to protect from inunda- 
tion and to reclaim from inundation once 
they are flooded. Reclamation may not 
be economical in some instances /9/. 

The Delta is an important agricultural 
area of California and of the United 
States. Historically, the area was 
noted for its truck crops, such as 
asparagus, f>otatoes, and celery, but 
since the 1920s there has been a shift 
toward lower-valued field crops. Corn, 
grain, hay, and pasture currently 
account for more than 75 percent of the 
region's total production. The change 
has been attributed mainly to market 
conditions, although technological 
change and changes in growing conditions 
have also played a role. 

The Delta lies in several counties 
(agricultural statistics are compiled by 
counties, not by geographic regions), 
but it is estimated that the Delta pro- 
duced $314 million worth of agricultural 
commodities in 1979, which would be 
about 3-1/2 percent of the statewide 



46 



total for that year. California is the 
number one agricultural state. 

As in the rest of California, farming in 
the Delta depends on irrigation. The 
irrigation water comes from the Delta 
channels, and with 700 miles of them 
weaving through the region, no field is 
far from a water source. Lying at sea 
level and contiguous with San Francisco 
Bay, the channels are always filled with 
water, but the quality of that water is 
not necessarily assured. Water quality 
is one of the historical water problems 
in Delta agriculture (the other major 
ones being flooding and drainage), and 
water quality continues to affect 
farming practices and productivity in 
varying degrees, depending on location 
in the Delta and year-to-year 
hydrology. 

Agriculture is one of the Delta water 
uses specifically protected by the State 
Water Resources Control Board standards 
of Decision 1485. The Exhibit A 
standards of the proposed Coordinated 
Operation Agreement would provide the 
same protection. 

According to the environmental impact 
report written for Decision 1485, "the 
level of protection provided to Delta 
agriculture (by the standards) would be 
that v^ich would have been available in 
the absence of the project". This does 
not mean water quality under Decision 
1485 would be the same as without the 
projects — it might sometimes be 
better, sometimes worse — but rather 
that it would be functionally equivalent 
for agricultural purposes during the 
irrigation season, April 1 to August 15. 
The scope of protection for agriculture 
in Decision 1485 excludes the southern 
Delta. The Board found, "the SWP and 
CVP facilities covered by the permits 
before the Board in this proceeding do 
not appear to have a direct impact on 
water quality conditions in the southern 
Delta." 

The water quality standards listed under 
the "Agriculture" heading of Exhibit A 



are based on a determination by the 
State Water Resources Control Board that 
irrigation water salinity of not more 
than 0.45 millimhos per centimeter EC is 
required to obtain full yield of corn in 
Delta organic soils. Corn was chosen as 
a representative crop of the region. 
Decision 1485, and hence Exhibit A, 
generally requires channel water salin- 
ity in agricultural areas of the Delta 
to be 0.45 millimhos or lower, but 
higher salinities are allowed for one or 
more of the following conditions: 

(1) late in the irrigation season, 

(2) western Delta, (3) other than "wet 
year". 

In May 1983, the Department of Water 
Resources, the State Water Resources 
Control Board, the University of Calif- 
ornia, and the U. S. Salinity Laboratory 
completed a study to further define the 
water quality needs of com in the 
Delta. The study, referred to as the 
"Corn Study", resulted in findings that 
corn growing in organic soils of the 
Delta is not as sensitive to salinity in 
irrigation water as was believed, nor 
does salinity necessarily concentrate in 
the root zone to the degree assumed in 
the formulation of Decision 1485. With 
subirrigation (which is common practice) 
and normal rainfall, irrigation water of 
2.20 millimhos EC can be used; with 
below normal rainfall, irrigation water 
of 0.80 millimhos EC was found to be 
usable without yield loss. Poorer 
quality irrigation water was also found 
usable without yield loss, depending on 
rainfall, soil properties, leaching 
practices, irrigation techniques, and 
the elevation and salt concentration of 
the water table. Irrigation water of 
1.9 millimhos EC was found usable 
without yield loss under "normal 
conditions" /lO/. 



Delta Municipal and 
Industrial Uses 

The western Delta includes some impor- 
tant industrial areas in eastern Contra 
Costa County, and water from the Delta 



47 



supplies a number of cities within the 
region. Thus, local municipal and 
industrial use, apart from such use in 
areas that receive Delta export water, 
is a consideration in regard to any 
issue involving disposition of Delta 
water supplies or Delta water quality 
control . 

Western Delta municipal and industrial 
water users obtain their supplies in two 
ways: directly from the channels, or 
from the Contra Costa Canal. The latter 
is a Central Valley Project facility 
that diverts from Rock Slough. The 
direct diverters obtain their supplies 
from the San Joaquin River and adjacent 
channels off the Contra Costa County 
shoreline in the Antioch-Pittsburg area, 
but they can also take water from the 
Contra Costa Canal if offshore water is 
unsuitable . 

The Contra Costa Water District is the 
water distribution authority for the 
Contra Costa Canal, but it also diverts 
water directly from Mallard Slough, 
opposite Chipps Island, when the chlor- 
ide ion content of the water there is 
100 parts per million (ppm) or less 
(mean tidal cycle). Historical avail- 
ability of water of this quality at 
Mallard Slough has varied from days in 
the 1976-77 water year to 365 days in 
1982-83. Average availability is about 
140 days per year. 

The only other direct municipal diverter 
is the City of Antioch, which diverts 
its total requirements from areas off- 
shore and adjacent to the city whenever 
the chloride ion content of the water 
there at high-high tide is 250 ppm or 
less (of the four-tide cycle, this is 
the highest tide). The Environmental 
Protection Agency's Drinking Water 
Regulations under Public Law 93-523 
recommend 250 ppm chloride as a maximum. 
Historical availability of this quality 
of water has varied from days in 
1976-77 to 365 days in 1982-83. Average 
availability is about 200 days per 
year. 



The extensive industrial complex 
adjacent to the San Joaquin River in the 
Antioch-Pittsburg area is located there 
partly because of the availability of 
large quantities of water for processing 
and cooling. The industries have three 
possible Delta water sources: 

" Water diverted directly from the San 
Joaquin River or New York Slough. 

° Raw water purchased from Contra Costa 
Water District conveyed from Rock 
Slough via the Contra Costa Canal; or, 
in the Pittsburg area, pumped from 
Mallard Slough at the District's 
pumping plant . 

° Treated water purchased from municipal 
purveyors who obtain their raw water 
from the Contra Costa Canal or a San 
Joaquin River diversion. 

The estimated cost of water pumped 
directly from the industries' own off- 
shore facilities was $3 per acre-foot in 
1981; raw water purchased from Contra 
Costa County Water District and conveyed 
through the Contra Costa Canal costs 
about $10 per acre-foot, and treated 
water purchased from municipal purveyors 
costs about $39 per acre-foot. 

Companies with facilities in the 
Antioch-Pittsburg area include Louisiana 
Pacific, Dow Chemical Corporation, Johns 
Manville, Pacific Gas and Electric, 
U. S. Steel, Crown Zellerbach, and 
DuPont . Their operations require boiler 
feed water, cooling water, and process 
water. Pacific Gas and Electric uses 
far more Delta water than any other 
company, but only for once- through 
cooling in its power plants — a use not 
much affected by salinity changes. 
Louisiana Pacific and Crown Zellerbach, 
paper products manufacturers located on 
the south shore of the San Joaquin River 
east of Antioch, are examples of the 
major industrial water users whose uses 
are sensitive to salinity. They both 
require process water of no more than 
150 ppm chloride. 



48 



In Decision 1485, the 
not include standards 
quality off the shore 
Costa County, but ins 
protect water quality 
industrial use with s 
Rock Slough intake of 
Canal. The Board rea 
canal provided a sati 
for direct diversion. 



State Board did 

to protect water 
line of Contra 
tead chose to 

for municipal and 
tandards for the 

the Contra Costa 
soned that the 
sfactory substitute 



Under Decision 1485, chloride content of 
the water at Rock Slough is required to 
be 150 ppm or less for a minimum of 
155 days per year and may not exceed 
250 ppm. Water for Contra Costa Canal 
is provided under a contract with the 
Bureau of Reclamation, but the contract 
contains no specific salinity criteria. 

Although not protected by Decision 1485, 
usable water continues to be available 
for direct diversion in the Antioch- 
Pittsburg area, depending on prevailing 
hydrology. An operation study (DWR 
PCSTAGE, March 7, 1983) indicates that 
in conditions that would exist in the 
year 2000 if no additional Central 
Valley Project or State Water Project 
facilities are constructed, water of 
250 ppm chloride or less will be avail- 
able at Antioch an average of about 
5 months per year. These would be 
months of relatively high runoff. 



Fish 

The estuary supports about 90 species of 
fish, of which the most important are 
the anadromous species chinook salmon, 
striped bass, sturgeon, American shad, 
and steelhead rainbow trout. All of 
these anadromous fish spend most of 
their adult lives either in the lower 
bays of the estuary or in the ocean. 
The Delta is a major nursery area for 
most of these species. Some species of 
fish reside in the Delta permanently, 
with the v*iite catfish prominent among 
them. The larger fish represent the top 
of a food chain that extends down to 
tiny phytoplankton, with each link in 
the chain fulfilling a vital role. 



Sport fishing is one of the major 
beneficial uses of the waters of the 
estuary. Commercial fishing within the 
estuary is much less important, being 
banned by law for major species such as 
striped bass and salmon. However, 
salmon migrating through the estuary 
account for about 80 percent of the 
commercial chinook salmon catch in ocean 
waters near San Francisco. These salmon 
have historically represented an annual 
return to the industry of $5.24 million 
at 1982 prices. The sport fishery for 
salmon in the estuary was valued at 
$10 million annually in 1982. The 
striped bass fishery, reserved exclu- 
sively for non-commercial anglers, was 
valued at $39 million in 1982 /!!/. 
Other fish in the estuary — including 
catfish, black bass, crappie, and blue- 
gill — also contribute significantly to 
recreation opportunities and the local 
economy. 

The Delta-Bay ecosystem is large, com- 
plex, and dynamic, so its workings are 
not and may never be completely under- 
stood. As regards the environmental 
requirements of the more abundant fish 
species, Chapter 4 of a September 1982, 
Department of Water Resources and 
Department of Fish and Game publication 
entitled "Draft EIR, Proposed Agreement 
to Manage Fish and Wildlife Resources, 
Sacramento- San Joaquin Estuary" summar- 
izes the current state of knowledge. In 
general, fish in the Delta require 
certain amounts and qualities of water 
to migrate, spawn, grow, and survive. 
Flows provided by the Central Valley 
Project and State Water Project are par- 
tially responsible for support of many 
species. Some aspects of project opera- 
tions are also detrimental to fish. 

Striped bass, frequently used as an 
indicator of the health of the 
ecosystem, have been in decline since 
the early 1960s. Various hypotheses 
have been advanced to explain this 
decline. Some of the hypotheses link 
the decline to operation of the CVP and 
SWP, particularly to the increase in 
total diversion from the Delta since the 



49 



beginning of SWP operation and effects 
associated with that increase. 

Whether or not project operations are 
responsible for the striped bass 
decline, they certainly have an impor- 
tant role in controlling key factors 
that affect the ecosystem, particularly 
water quality and flows in the Delta. 
The rate at which the projects are 
exporting water from the southern Delta 
affects Delta outflow, which in turn 
affects the amount of ocean salinity 
that may advance up the estuary. The 
export rate can also affect the direc- 
tion of flow in many Delta channels. In 
the drier times of most years, some 
Delta channels flow toward the CVP and 
SWP pumping plants rather than toward 
San Francisco Bay. 

As regards control of ocean salinity, 
operation of the projects assures the 
Delta of less salinity intrusion than 
would occur without the projects, 
because the projects are operated to 
control salinity in the Delta and must 
do so to protect the quality of the 
export water. Releases from project 
reservoirs keep salinity in check during 
the dry season, but project operations 
reduce total Delta outflow over the full 
water year, allowing salinity to advance 
farther into the estuary at certain 
times than it would at those times under 
uncontrolled conditions. 

Biological productivity in the estuary 
is highest in the zone where freshwater 
Delta outflows meet and mix with more 
saline waters of the bay. This 
"entrapment zone" concentrates 
sediments, nutrients, phytoplankton, 
striped bass larvae, and fish food 
organisms. It is considered 
advantageous that outflows be sufficient 
to keep the entrapment zone in the upper 
reaches of Suisun Bay, where it can 
spread out over a large area, rather 
than in the narrower Delta channels 
upstream from Suisun Bay. 

Apart from salinity control, flows 
caused, provided, or controlled by the 



CVP and SWP affect fish in numerous 
ways. Flow toward the project pumps 
draws both fish and fish food organisms 
into the export facilities. Larger fish 
are screened out, but smaller fish and 
fish food pass through and leave the 
Delta. Many of the larger fish do not 
survive screening and subsequent 
handling. The draw of the pumps may 
cause water to flow too fast for optimal 
fish food production in some channels, 
and the reverse (upstream) flows in some 
channels may confuse migrating fish. 
Downstream flows carry out-migrant 
anadroraous fish to the ocean. 

Factors besides CVP and SWP operations 
that affect fish dependent on the Delta- 
Bay ecosystem include water diversions 
within the Delta, diversions upstream, 
water pollution, agricultural return 
flows, fishing, and natural predator- 
prey interactions. 

Striped Bass . Operation of the pro- 
jects, and the resulting water qualities 
at various places in the Delta, affects 
abundance and distribution of striped 
bass in all phases of their life 
history. As described in Chapter 4 of 
the Final Environmental Impact Report on 
the Proposed Agreement to Manage Fish 
and Wildlife Resources of the 
Sacramento-San Joaquin Estuary, the 
number of adult striped bass in the 
estuary is partially determined by CVP 
and SWP exports from the southern Delta, 
salinity in certain Delta channels, 
outflows, and direction and velocity of 
flow through the Delta. 

More than half the striped bass spawn 
in the Sacramento River, and an 
estimated 33 to 45 percent spawn in 
the San Joaquin River and adjacent 
sloughs between Antioch and the 
vicinity of Venice Island. The fish 
that spawn in the San Joaquin River 
prefer salinities below about 200 ppm 
TDS , but laboratory studies indicate 
that salinities up to 1,000 ppm do 
not affect egg survival. April is 
the month of highest concern. 



50 



Delta outflow is important for young 
striped bass and Neomysis shrimp, an 
important bass food source. Although 
information is lacking for a complete 
understanding of the factors controlling 
the young striped bass population, Delta 
outflow in the spring and early summer 
is believed significant. Maintenance of 
the entrapment zone in the Suisun Bay 
area (at outflows of about 4,000 to 
6,000 cfs) is one beneficial function of 
outflow. At lower levels, the entrap- 
ment zone moves upstream into the less 
productive area around Antioch; and at 
extremely low levels, it moves into the 
western Delta. 

Level and timing of exports from the 
southern Delta affect the number of 
striped bass eggs, larvae, and juveniles 
exposed to removal from the Delta with 
export water. Eggs and larvae, abundant 
from May through July, cannot be 
screened from export water; and the 
screening efficiency for small striped 
bass, abundant in July and August, is 
low at the present fish protective 
facilities. Higher exports at these 
times, therefore, impact striped bass to 
a higher degree than exports made in the 
fall and winter, when striped bass are 
less abundant in the southern Delta and 
can be screened fairly efficiently. 

Flow patterns in the Delta affect the 
abundance of juvenile striped bass and 
their food supply. The most harmful 
project-induced flows are the reverse 
flows in the lower San Joaquin River, 
which draw young fish out of the western 
Delta toward the export pumps. 



Salmon . Operation of the State Water 
Project and Central Valley Project in 
the Delta affects in-migrant (adult) and 
out-migrant (juvenile) chinook salmon on 
their way to and from spawning and 
nursery areas in the Sacramento and San 
Joaquin river systems. More than 
90 percent of the Central Valley's 
Chinook salmon are produced in the 
Sacramento River system. Flow direction 
and velocity in Delta channels, opera- 
tion of the Delta Cross Channel, and 
exposure of fish to the export pumps are 
the major project-related factors 
affecting salmon survival. 

Adult salmon require the presence of 
homestream water to guide them to their 
spawning grounds. Salmon using the San 
Joaquin River are seriously affected by 
SWP and CVP operation in this regard, 
since at many times virtually all San 
Joaquin River water is being exported. 

Salmon from the Sacramento River system, 
migrating through the Delta as juveniles 
on their way to the ocean in the spring 
and early summer, are sometimes affected 
by reverse flows in the lower San 
Joaquin River. They are also affected 
by diversion into the interior Delta 
through the Delta Cross Channel, where 
survival is lower than if they continued 
downstream in the Sacramento River. 

The exposure of chinook salmon to the 
SWP and CVP fish screens causes losses 
due to predation by larger fish in front 
of the screens, screen inefficiencies, 
and attrition in the process of handling 
and hauling screened fish. 



Decision 1485 protects striped bass 
spawning requirements with standards 
specifying the maximum salinity allow- 
able in the lower San Joaquin River 
between Venice Island and Antioch from 
April 1 to May 5. From May 6 through 
the end of July, survival requirements 
of young striped bass are protected by 
standards specifying minimum allowable 
Delta outflow and limiting project 
export rates . 



Decision 1485 protects migrating salmon 
with year-round minimum flow require- 
ments for the Sacramento River at Rio 
Vista. 



Wildlife 

The complex interface between land and 
water in the Delta-Bay estuary provides 
rich and varied habitat for wildlife, 



51 



especially birds. The Delta and Suisun 
Marsh are particularly important to 
waterfowl migrating via the Pacific 

Flyway . 

In the Delta, the principal attraction 
for waterfowl is winter-flooded 
agricultural fields — mainly cereal 
crops -- which provide food and 
extensive seasonal wetlands. The Delta, 
along with other principal wetlands that 
support Central Valley waterfowl, is 
winter habitat for 60 percent of the 
waterfowl on the Pacific Flyway, and for 
91 percent of all waterfowl that winter 
in California. More than a million 
waterfowl are frequently in the Delta at 
one time /12/. 

In Suisun Marsh, waterfowl use public 
and private wetlands managed for water- 
fowl habitat and recreational hunting. 
During the fall of dry years, the marsh 
has provided feeding and resting areas 
for up to 28 percent of California 
waterfowl, amounting to as many as one 
million birds /13/. Species of ducks 
wintering in the area include pintail, 
shoveler, mallard, widgeon, greenwinged 
teal, ruddy duck, canvasback, scaups, 
gadwall, bufflehead, and scoter. Geese, 
though much less common than ducks, are 
represented by Canada, snow, and 
white-fronted species. 

Protection for growth requirements of 
the plants that provide food for ducks 
in the Suisun Marsh are included in 
Decision 1485 standards and are part of 
ongoing negotiations and protective 
facility development. 

Small mammals also find suitable habitat 
in the Delta, Suisun Marsh, and upland 
areas. Vegetated levees, remnants of 
riparian forest, and undeveloped islands 
provide some of the best mammalian 
habitats in the region. Species include 
muskrat , mink, river otter, beaver, 
raccoon, gray fox, and skunks. 

The area also supports a variety of 
non-game wildlife, including songbirds, 
hawks, owls, reptiles, and amphibians. 



Rare and Endangered Species 

Eight rare or endangered vertebrate 
species, including the southern bald 
eagle and the Aleutian Canada goose have 
been observed in the Delta, but none are 
confined exclusively to the Delta. 
Several rare invertebrates and many rare 
plant species also occur in the Delta; 
most are limited to freshwater marsh or 
vernal pool habitats. Project opera- 
tions, by determining water quality 
distribution, affect some of the rare 
plants that depend on brackish water for 
survival . 

Tables 6 and 7 list rare, endangered, 
and threatened species occurring in or 
near the Delta and in other areas \Aiere 
the Proposed Action could conceivably 
have some effect. 



San Francisco Bay Complex 

San Francisco Bay is the largest bay on 
the California Coast. The bay has a 
water surface area of about 420 square 
miles at mean high water, 274 miles of 
shoreline (not including islands), and 
about 130 square miles of adjacent tidal 
flats and marshes. 

The surface hydrology of the bay can be 
divided into two distinct patterns. The 
northern bay, including San Pablo and 
Suisun bays, receives freshwater outflow 
from the Sacramento-San Joaquin Delta, 
and it functions as part of the 
Delta-Bay estuary. The southern bay 
receives scant runoff, and behaves like 
a lagoon. Circulation in and flushing 
of the Bay depends on tides and Delta 
outflow. Circulation is primarily a 
tidal process, while flushing is 
believed to depend on tidal action 
supplemented by periodic Delta outflow 
surges following winter storms. 

San Francisco Bay supports marine fish 
and invertebrates and serves as a 
migration path for anadroraous species. 
Popular sport fish include striped bass, 
surf perch, jacksmelt, and topsmelt. 



52 



TAle 6 

RARE, THREATENED, AND ENDANGERED ANIMALS IN OR NEAR THE 
SACRAICNTO-SAN JOAQUIN DELTA AND THE DRAINAGE CF THE SACRAtCNTO RIVER 



CoBwion Name 

Lange's metalmark 
butterfly 

Valley elderberry 
longhorn beetle 

CaliTornia fresh- 
water shrimp 

Shasta salamander 



Giant garter 
snake 



Aleutian Canada 
goose 



Scientific Name Status* 



Habitat and Distribution 



Swainson's 
hawk 

Bald eagle 



Peregrine 
falcon 



California 
clapper rail 

Black rail 

California 
yellow-bil led 
cuckoo 

Least Bell's 
vireo 

Saltmarsh 
yellowthroat 



Salt marsh 
harvest mouse 



Apodemia mormo FE 

langei 



Desmocerus cali- 



FT 



fornicus dimorphus 
Syncaris pacifica SE, FC 



Hydromantes 
shastae 

Thamnophis 
couchi gigas 



SR, FC 



SR 



Branta canadensis SE 
leucopareia 



Buteo swainsoni SR, FC 



Haliaeetus 
leucocephalus 



FE, SE 



Falco peregrinus FE, SE 



Rallus longirost- FE, SE 
ris obsoletus 

Laterallus jamai- SR, FC 
censis coturniculus 

Coccyzus ameri- SR, FC 
canus occidcntalis 



Vireo bellii SE, FC 
pusillus 



Geothlypis FC 

trichas sinuosa 



Reithrodontomys FE, SE 
raviventris 



Antioch sand dunes; 
County 



Contra Costa 



Elderberry bushes near rivers; 
Sacramento arxJ Solano Counties 

Streams; Marin, Napa, and Sonoma 
Counties 

Limestone fissures and caves near 
Shasta Lake; Shasta County 

Freshwater marsh, riparian areas, 
rice fields, canals; Central 
Valley floor from Butte County 
to Fresno County 

Valley grassland, freshwater 
marsh, harvested fields, green 
barley and wheat fields; winters 
mainly in Sacramento and San 
Joaquin Valleys, minor use in 
Delta 

Grasslands, irrigated pastures, 
open fields; winters mainly in 
Central Valley and Klamath Basin 

Lake margins and river courses; 
breeds in northern California; 
winters in most of State except 
for deserts 



Breeds on cliffs in mountains 
and near coast; feeds and winters 
near coastal and inland marshes 
and riparian areas 

Salt marshes; Sonoma County to 
Santa Clara County 

Salt, brackish, and fresh marshes 
Marin Coufity to San Diego County 

Riparian areas, orchards near 
streams; 7 rivers from Tehama 
County to Imperial County 

Riparian areas; Santa Barbara 
to San Diego County 

Fresh marshes for breeding, salt 
and brackish marshes in winter; 
breeds Sonoma County to San 
Mateo County 

Salt marshes; Sonoma County to 
San Mateo County 



CQA Feature Near 
Occurrence of Species 

San Joaquin River in 
the Delta 

Lower American River 



Several miles from 
the Delta 

Shasta Lake 

Sacramento River, 
Feather River, telta 



Delta 



Sacramento, Feather, 
and American Rivers 



Shasta Lake, Whiskey- 
tovn Reservoir, Clair 
Engle, Folsom, and 
Oroville Lakes, and 
San Luis Reservoir 

Sacramento, Feather, 
and American Rivers, 
and Delta 



Delta, San Francisco 
Bay 

Delta, San Francisco 
Bay 

Sacramento and 
Feather Rivers 



Formerly near Sacra- 
mento, Feather, and 
American Rivers 

Delta, San Francisco 
Bay 



Delta, San Francisco 

Bay 



» Status: FE = Federal Endangered 
SR = State Rare 



FT r Federal Threatened 
SE = State Endangered 



FC = Federal Candidate 



53 



Shellfish include mussels, oysters, 
clams, crabs, and shrimp. 

Seasonal variations in salinities affect 
the seasonal distribution and survival 
of aquatic organisms. Benthic (bottom 
dwelling) invertebrates, such as clams, 
are limited to areas v*iere conditions 
are favorable year-round. 



Around the bay, three habitat types are 
found: open water, tidal mudflats, and 
marshland. Such habitats are used by 
various species, but mainly shorebirds 
and waterfowl. 

The bay has been impacted by many 
factors, including pollution, land 
reclamation, ship channels, and sediment 



Table 7 

RARE AND CNOANGEREO PUNTS IN OR NEAR THE 
SACRAMENTO-SAN XAQUIN DELTA AND THE DRAINAGE OF THE SACRAMENTO RIVER 



Cornwon Name 

Contra Costa 
wallflower 

Aiitioch CXjiics 
evening primrose 

Suisuii aster 



California 
hibiscus 

Delta tule-pea 



Mason's 
lilaeopsis 

Valley 
sagittaria 

Slender orcutt 
grass 



Scientific Name 



Status* 



Erysimum capital um FE, SE 
var. angustatus 



Oenothera del- 



toides howellii 



Aster chiletisis 
var . lent us 

Hibiscus 
californicus 



Lilaeopsis 
masonii 

Sagittaria 
sanfordii 

Orcuttia tenuis 



FE, SE 



FC 



FC 



Lathyrus jepsonii FC 
ssp . jepsonii 



FC 



SE 



Habitat and Distribution 

Loose sand; Antioch Dunes, 
Contra Costa County 

Loose sand; Antioch (Xines, 
Contra Costa County 



CQA Feature Near 
Occurrence of Species 

Delta 



Delta 



Coastal salt marshes; Suisui Bay, Cblta 
Solaix) County 

Freshwater marshes; Contra Costa Delta 
County and San Joaquin County 



Freshwater marshes; Suisui and 
San Pablo Bays 



SR, FC Mudflats; Delta 



Delta 



Delta 



Sloughs and sluggish streams, Sacramento River, 

freshwater marsh; Central Valley Delta 

Vernal pools in valley grassland Sacramento River 
and foothill woodland; Shasta, 
Tehama, and Lake Counties 



Greene's orcutt 
grass 



Orcuttia greenei 



SR Moist open places in valley 

grassland; Tehama to Tulare 
Counties 



Sacrsmiento River 



Hairy orcutt 
grass 

Sticky orcutt 
grass 

Colusa grass 



Orcuttia 


pilosa 


Orcuttia 


viscida 


Neostapfi 


a 


colusana 



SE 



SE 



SE 



Vernal pools in valley grassland; Sacramento River 
Stanislaus to Madera Counties 



Valley grassland; Sacramento 
County 



American River 



Vernal pools in valley grassland; Sacramento River 

Colusa, Stanislaus, and Merced 

Counties 



♦ Status: FE = Federal Endangered 
SR = State Rare 



FC = Federal CaixJidate 
SE = State Endangered 



54 



load from early gold mining activity. 
The potential effect on the bay of the 
CVP and SWP, as well as other projects 
such as Hetch Hetchy and Mokelumne River 
Aqueduct and overall availability of 
freshwater inflow, is being studied, but 
results are several years away. 



Environmental Consequences, 
Delta-Bay Estuary 

This section compares the environmental 
conditions expected in the Delta-Bay 
estuary with the Proposed Action to 
corresponding conditions expected with 
No Action, Case A. Case A is the No 
Action scenario in v^iich both the 
Central Valley Project and the State 
Water Project are operated to meet only 
the Tracy standards for Delta water 
quality in critical years. With the 
Proposed Action, both projects would be 
operated for the Exhibit A standards of 
the Coordinated Operation Agreement in 
all years, including critical years. 
With the Proposed Action and with all No 
Action cases A, both projects would be 
operated to meet the Exhibit A standards 
in years other than critical. 

No Action Cases B and C are not specifi- 
cally evaluated, but their consequences 
can be estimated by reference to the 
consequences of the Proposed Action and 
No Action, Case A. No Action, Case B, 
is the scenario in vAiich the CVP is 
operated for the Tracy standards in 
critical years, while the SWP operates 
as if the Exhibit A standards are in 
effect; i.e., releases its share of the 
additional water needed to meet 
Exhibit A standards. Environmental 
consequences of No Action, Case B, in 
the Delta-Bay estuary would be inter- 
mediate between those of Proposed Action 
and No Action, Case A, but Case B condi- 
tions are not quantified or specifically 
described except in Table 4, Chapter 3. 
No Action, Case C, is the scenario in 
which the CVP is operated for the Tracy 
standards in critical years while the 
SWP provides all additional water needed 
to meet Exhibit A. The environmental 



consequences of No Action, Case C, in 
the Delta-Bay estuary, would be similar 
to those of the Proposed Action. 



Delta Agriculture 

Operation of the CVP and SWP affects 
water qualities for agriculture differ- 
ently in different parts of the Delta. 
The parts of the Delta that have good 
hydraulic connections to the Delta Cross 
Channel, through which project water 
runs directly from the Sacramento River, 
benefit most. The other parts of the 
Delta are less advantageously situated. 

Proposed Action . Implementing the 
Proposed Action would have no adverse 
effects on Delta agriculture, as 
compared to No Action, Case A. 

Water quality conditions for agriculture 
in critical years would be better with 
the Proposed Action. 

No Action . Operation study results for 
critical years indicate that water 
quality conditions in No Action, Case A, 
would be significantly worse for Delta 
agriculture than conditions in the 
Proposed Action. Small adverse 
differences having potential to affect 
salt-sensitive crops were observable at 
most stations throughout the Delta in 
results from DWR's PCSTAGE and EIRSALT 
computer models. The major difference, 
however, was observable at the station 
representing Emmaton, ^ich is on the 
north side of Sherman Island near the 
mouth of the Sacramento River. Salinity 
at Emmaton is indicative of salinity in 
the western Delta. 

Monthly average salinities at Emmaton 
during the irrigation season, in 
raillimhos per centimeter EC (electrical 
conductivity), for the six critical 
years modeled at the 1980 level of 
development, with the Tracy standards 
controlling in No Action, Case A, and 
the Exhibit A standards controlling in 
the Proposed Action, are as follows 
(values at higher-high tide): 



55 



Proposed 
Action 

No Action, 
Case A 



Apr May J un Jul Aug Sep 



0.9 0.9 1.2 1.6 1.9 2.4 



1.9 1.9 1.8 2.3 2.8 3.2 



In either case, salinities would be high 
enough to impair full yields of crops 
normally grown in the area, such as 
corn, but growers v»uld face much more 
severe salinity problems in No Action, 
Case A. High salinity early in the 
irrigation season, when plants are 
germinating, would be particularly 
damaging. A significant reduction in 
crop yields during critical years should 
be expected in No Action, Case A. In 
the Proposed Action, full or nearly full 
yields of corn or asparagus could be 
obtained in critical years with careful 
management and adequate leaching. 



Municipal and 
Industrial Use 

The following analysis is based on the 
State Water Resources Control Board's 
Final Environmental Impact Report for 
Decision 1485 and on the operation 
studies described in Chapter 3. 

Proposed Action . Implementing the 
Proposed Action would have no adverse 
effects on local municipal and indust- 
rial users of Delta waters, compared to 
No Action, Case A. Operation study 
results (Figure 11) indicate that with 
the Exhibit A standards controlling in 
the Delta, salinity of the water 
available at Rock Slough for diversion 
into the Contra Costa Canal would stay 
within the quality range acceptable for 
municipal and industrial use (150 ppra 
chloride or less) . The values plotted 
on Figure 11 are from monthly salinity 
values projected through the six 



200 



a. 

Q. 

CO 
UJ 
Q 
CL 
O 
_i 
I 
O 



FIGURE 11 
INCREMENTAL BENEFITS IN CHLORIDES AT ROCK SLOUGH 
PROPOSED ACTION VS NO ACTION - CASE A 




JAN FEB MAR APR 



_1_ 




MAY JUN JUL AUG 
CRITICAL YEARS 



SEP OCT NOV DEC 



56 



historical critical years modeled at the 
1980 development level. 

No Action . Replacing the Proposed 
Action's Exhibit A standards with the 
Bureau' s Tracy standards as the control- 
ling criteria for Delta water quality in 
critical years wjuld adversely affect 
local municipal and industrial users of 
Delta waters. 

Direct diversion would be affected 
little, if at all, because salinity of 
the water offshore from Contra Costa 
County in critical years would be above 
the maximum levels acceptable for direct 
diversion virtually all the time, 
regardless of which criteria controlled. 
Thus, the effect on the quality of 
substitute supplies from the Contra 
Costa Canal is more significant. 

Under the Exhibit A criteria of the 
Proposed Action, chloride at the Rock 
Slough intake of the Contra Costa Canal 
is required to be 150 ppm or less for 
at least 155 days each year and may 
not exceed 250 ppm at any time. State- 
wide project operation study results 
indicate that these requirements would 
be more than met in a critical year. 
With the Tracy criteria replacing 
Exhibit A, operation studies indicate 
that the Exhibit A criterion of 150 ppm 
chloride for 155 days would be met 
in critical years, but the 250 ppm 
maximum chloride limit wDuld occasion- 
ally be exceeded. EPA's recommended 
maximum of 500 ppm TDS would also be 
exceeded occasionally with the Tracy 
criteria controlling. Chloride and 
TDS concentrations exceeding the 
recommended maxima may be objection- 
able, but are not in themselves 
considered hazardous to health. 

High chloride concentrations at the 
Rock Slough intake may be indicative 
of sea water intrusion, and sea water 
contains bromides that promote the 
formation of trihaloraethanes when 
water is chlorinated for municipal 
use. Tr ihalomethanes are suspected 
carcinogens (cancer-causing agents). 



The EPA standard for the maximum 
concentration of trihalomethanes in 
drinking water is 100 parts per billion, 
Contra Costa Water District has found 
that v^en its raw water supplies, such 
as from the Contra Costa Canal, contain 
chloride in excess of 100 parts per 
million, the water after chlorination 
will contain trihalomethanes at levels 
above the EPA standard. To control 
trihalomethane formation, the district 
has implemented an ammonia treatment 
process. This inexpensive process has 
been found effective in keeping 
trihalomethane concentrations to below 
the EPA standard. 

With the Tracy standards controlling in 
critical years, chlorides in Contra 
Costa Canal water would frequently 
exceed 150 ppm. During the 1976-77 
drought, such chloride levels required 
modifications in the process used to 
produce salt-sensitive papers and 
cardboard at the Crown Zellerbach and 
Louisiana Pacific (then Fibreboard) 
plants near Antioch. These modifica- 
tions increase production costs and 
limit production capacity. 



Fish 

Information in this section concerning 
the Delta and Suisun Marsh is based 
largely on material provided by the 
California Department of Fish and Game. 
Information concerning rivers and 
upstream reservoirs was provided by the 
U, S. Fish and Wildlife Service. 

Operation of the Central Valley Project 
and State Water Project is believed to 
be one of many factors affecting fish in 
the Delta-Bay estuary. The Proposed 
Action would provide important protec- 
tion for fish that would be sacrificed 
in the driest years (critical years) 
with No Action, Case A. 

Proposed Action . For striped bass, the 
Proposed Action would be expected to 
have the following consequences: 



57 



Salinity in the Lower San Joaquin 
River. Operation studies using the 
hydrology of the 1928-1934 critical 
period indicate salinities in the San 
Joaquin River at San Andreas Shoals 
(within the spawning area) ranging 
from 75 to 192 ppra TDS. These 
salinities are well within the range 
considered suitable for striped bass 
spawning. 

Delta Outflow. Exhibit A standards of 
the proposed Coordinated Operation 
Agreement give an assurance of ample 
outflow to maintain an entrapment zone 
favorable to the growth and survival 
of young striped bass. Summer flows 
during critical years are in the range 
of 3,500 to 4,500 cfs, and flows 
earlier in the year are higher. 

° CVP and SWP Exports. The export limi- 
tations imposed by Exhibit A in May, 
June, and July reduce diversion of 
striped bass eggs and larvae (compared 
to unrestricted pumping). Losses at 
the export pumps are still high, how- 
ever, especially in drier years when 
flows are low and a higher percentage 
of Delta inflow is diverted. 

For salmon, the Proposed Action would be 
expected to have the following conse- 
quences : 

Flow in Delta Channels. The Proposed 
Action would provide minimum flow 
standards at Rio Vista and provide for 
control standards at the Delta Cross 
Channel to minimize cross-Delta 
movement of salmon. 

° CVP and SWP Exports, May and June 
export limitations that would be 
observed by the projects under the 
Proposed Action would decrease the 
exposure of salmon to the export 
pumps, as compared to unlimited 
pumping during those months. However, 
substantial losses would still occur. 

For San Francisco Bay, the Proposed 
Action, as compared to No Action, 
Case A, could have the effect of 



slightly lessening peak Delta outflows 
in the year or years immediately follow- 
ing critical years. However, Delta 
outflows during most years, including 
critical years, would be higher with the 
Proposed Action, and this would be 
beneficial to fish and wildlife of the 
estuary overall. 

Due to the outflow standards and export 
limitations described above, the Pro- 
posed Action would help to assure main- 
tenance of existing standards designed 
to protect fish and fish habitat in the 
Delta. 

No Action . For striped bass, No Action, 
Case A, would be expected to have the 
following consequences: 

Salinity in the Lower San Joaquin 
River. Operation studies using the 
hydrology of the 1928-1934 critical 
period indicate salinities in the San 
Joaquin River at San Andreas Shoals 
(within the spawning area) as high as 
279 ppm TDS in April, exceeding the 
level at v*iich striped bass prefer to 
spawn. 

Delta Outflow. With the Tracy stand- 
ards controlling in critical years, 
outflows would be 3,000 to 3,500 cfs 
in July, August, and September. These 
outflows are inadequate to maintain 
the entrapment zone in the Suisun Bay 
area, and decreases in Neomysis and 
young striped bass abundance would be 
expected. 

° CVP and SWP Exports. Operating the 
CVP and SWP to Tracy standards in 
critical years and to the provisions 
of Exhibit A in all other years would 
not change exports during the period 
when striped bass eggs and larvae are 
abundant. Therefore, there would be 
no difference in impacts associated 
with No Action, Case A. 

Flow in Delta Channels. Operation 
studies indicate that operating the 
CVP and SWP to meet the Tracy stand- 
ards in critical years rather than the 



58 



standards of Exhibit A would increase 
the magnitude of reverse flows in the 
lower San Joaquin River. With Tracy 
standards, critical year reverse flows 
in the lower San Joaquin average 
2,100 cfs. Such reverse flows would 
exacerbate an already detrimental 
condition. 

For salmon. No Action, Case A, would 
be expected to have the following 
consequences : 

Flow in Delta Channels. Operating the 
CVP and SWP to the Tracy standards in 
critical years would increase the 
frequency and magnitude of reverse 
flows in the lower San Joaquin River 
in April, causing an increase in the 
number of juvenile salmon from the 
Sacramento River that would be drawn 
to the export pumps. Also, flows in 
the Sacramento River would decrease in 
April, May, and June compared to 
operation for the Exhibit A standards, 
further reducing the survival of 
juvenile salmon migrating down the 
river . 

° CVP and SWP Exports. Operation 

studies at the 1980 and 2020 levels of 
development indicate virtually no 
change in exports during critical 
years v^en operating to the Tracy 
standards, as compared to exports in 
those same years when operating to the 
Exhibit A standards. Therefore, no 
adverse impact would be expected from 
operating to the Tracy standards. 
However, if the relaxation to Tracy 
standards were used to increase 
exports rather than to retain 
reservoir storage, all the adverse 
effects associated with exporting 
water from the Delta and transferring 
water across the Delta would be 
exacerbated. 

Abundance and distribution of resident 
fish in the Delta would not be expected 
to be significantly affected by substi- 
tuting the Tracy standards for those of 
Exhibit A in critical years. 



In general, critical year operation of 
the CVP and SWP would be more harmful to 
Delta fish under No Action, Case A, than 
it would be under the Proposed Action. 



Wildlife 

CVP and SWP operations have little 
observable effect on wildlife of the 
Delta-Bay estuary, except in Suisun 
Marsh. Protective measures, including 
facilities and agreements, are part of 
planning, and the Agreement specifies a 
methodology for incorporating Suisun 
Marsh protective features viien negotia- 
tions are completed. Accordingly, the 
analysis of environmental differences 
between the Proposed Action with planned 
marsh facilities and No Action Case A 
focuses on differences that would be 
observed in Suisun Marsh, much of v^ich 
is managed specifically for waterfowl. 
These differences would exist in 
critical years, assuming that the CVP 
and SWP would be operated to meet the 
Exhibit A standards under the Proposed 
Action and to meet the Tracy standards 
under No Action, Case A. 

The seeds of the alkali bulrush plant 
constitute the bulk of the winter food 
supply for waterfowl using Suisun Marsh. 
Therefore, production of this food 
directly relates to the marsh's water- 
fowl holding capacity. Production of 
alkali bulrush seeds is related to the 
salinity of the water in the Marsh, 
which is determined in part by project 
operations. Salinity during May has the 
best correlation to alkali bulrush seed 
production. 

A computer model of the marsh channels 
was employed to compare applied water 
salinities and resulting alkali bulrush 
seed production under No Action, Case A, 
and the Proposed Action combined with 
future marsh facilities for a critical 
year. Results of this comparison showed 
significant acreage increases with 
improved applied water salinities below 
11.0 EC. These studies are on file with 
the Department of Water Resources. 



59 



Relationships supplied by the Department 
of Fish and Game between applied water 
salinity categories and average produc- 
tion and germination of alkali bulrush 
seeds in Suisun Marsh shown in Table 8. 



TAle 8 

SALINITY RELATIONSHIP TO 

ALKALI BULRUSH SEED PRODUCTION 

AM) GERMINATION 



Percent of 
Electrical HaxlnuM Seed 
Conductivity Production 



To 11.1 

11.1 to 14.0 

14.1 and [p 



90 
60 
23 



Percent 
Germination 

60 
44 
16 



Applying the relationships in Table 8, 
conditions existing under the Proposed 
Action would maintain high alkali 
bulrush seed production and germination 
throughout larger areas of the marsh 
than would the modeled conditions under 
No Action, Case A. Therefore, the 
waterfowl holding capacity of the marsh 
would be greater under the Proposed 
Action. 



Rare, Threatened, and 
Endangered Species 

Neither the Proposed Action nor No 
Action, Case A, would significantly 
affect rare, threatened, or endangered 
species in the Delta-Bay estuary. 

Proposed Action. The Proposed Action 
would not affect rare, threatened, or 
endangered species in the Delta or 
Suisun Marsh. The marsh habitats of the 
California clapper rail, salt marsh 
harvest mouse, California black rail, 
and salt marsh yellowthroat are influ- 
enced by Delta outflow, which determines 
the level of salinity in the Delta-Bay 
marshes . 

At both the 1980 and 2020 levels. Delta 
outflows would be higher during criti- 
cally dry years with the Proposed Action 



than with No Action, Case A. The addi- 
tional outflow would cause less saline 
conditions in the estuary, favoring 
brackish marsh habitats over salt marsh 
habitats. Brackish marshes are pre- 
ferred by yellowthroat; salt marshes are 
preferred by the harvest mouse and black 
rails. Clapper rail inhabit both brack- 
ish and freshwater marshes. Critically 
dry years are infrequent, however, so 
there would be no appreciable difference 
in estuary marsh habitats between the 
Proposed Action and No Action, Case A, 
except temporary differences in the 
salinity of marsh waters and soils. 

Delta outflows with and without the 
Proposed Action are similar enough that 
there would be no effects on marshes in 
the San Francisco Bay area. Therefore, 
the Proposed Action would not affect 
California clapper rail, California 
black rail, salt marsh yellowthroat, and 
salt marsh harvest mouse in the bay 
area. 

The Proposed Action would not affect the 
California freshwater shrimp, since this 
species inhabits freshwater streams 
outside the Delta-Bay area. 

The Proposed Action would not affect the 
Aleutian Canada goose. Marsh vegetation 
at Grizzly Island and other areas 
occasionally used in the winter by this 
species would not be affected. During 
critically dry years, the Exhibit A 
standards would maintain higher quality 
water for Delta agriculture than would 
the Tracy standards of No Action, 
Case A. Crop yield would not be 
reduced, and Aleutian Canada geese would 
still be able to feed in the Delta. 

The Proposed Action would not increase 
areas of the Antioch dunes flooded by 
the San Joaquin River, and therefore 
would not affect the Lange's metalraark 
butterfly, Antioch dunes evening 
primrose. Contra Costa wallflower, and 
Suisun aster. Higher water quality 
associated with the Proposed Action, as 
compared to No Action, Case A, would be 
favorable for other Delta plant species. 



60 



However, a Delta outflow difference 
resulting in higher water quality would 
only occur in critically dry years. 

No Action . In No Action, Case A, at 
both the 1980 and 2020 levels. Delta 
outflow in critically dry years would be 
lower than it would be under the 
Proposed Action. Slightly higher 
salinities would result, temporarily 
making marshes more saline. The higher 
salinity would temporarily benefit 
harvest mice, black rails, and some 
clapper rails. No Action, Case A, would 
not affect the above species in San 
Francisco Bay, because bay hydraulics 
would not be significantly different, as 
compared to the Proposed Action. 

Aleutian Canada geese that use Grizzly 
Island and other Delta areas would not 
be affected, because marsh vegetation 
would not be changed. 



Affected Environment 
State Water Project Service Areas 

The State Water Project has water supply 
contracts with 30 public agencies vAiose 
jurisdictions encompass a fourth of the 
land area of California and two-thirds 
of the population. The areas receiving 
State Water Project water include most 
of Southern California, the southern 
part of the San Joaquin Valley, the San 
Francisco Bay area, and areas in the 
Feather River region of Northern 
California, from which State Water 
Project water originates. Figure 12 
shows the State Water Project con- 
tracting agencies and service areas,* 

Most of the State Water Project water 
delivered in Southern California and the 
San Francisco Bay area is for urban use, 
while most delivered in the San Joaquin 
Valley is for agricultural use. 
Contracts for delivery of water in the 
Feather River region represent only 



about 1 percent of the total under 
contract. The table accompanying 
Figure 12 identifies the State Water 
Project contracting agencies and shows 
the amounts of water for which they have 
contracted. 



Agricultural Uses 

The agricultural areas served by the 
State Water Project are mainly in Kings 
and Kern counties, and mainly in the 
western portions of these counties. The 
one exception is the Oak Flat Water 
District in western Stanislaus County. 
These areas relied on the State Water 
Project for 71 percent of their 
irrigation water supply in 1981, v*ien 
the estimated value of crops grown with 
SWP water was $474 million. Cotton 
accounted for 41 percent of this total; 
almonds, oranges, pistachios, grapes, 
cantaloupes, lettuce, onions, alfalfa 
seed and hay, and wheat together 
accounted for another 41 percent, and 
about 40 other crops accounted for the 
remainder /14/. 

The estimated values of SWP water to 
agricultural water users in future years 
(1983 dollars) are: 



Year 

1985 
1990 
1995 
2000 
2010 
2020 
2035 



Dollars per 
Acre-Foot 

168 
204 
224 
242 
264 
270 
276 



These values were determined using the 
Department of Water Resources Central 
Valley Agricultural Model, based on the 
increment in net farm income producible 
with increments in SWP agricultural 
supply. 



*Central Coastal area contractors of the SWP would be served by a Coastal Branch of 
the California Aqueduct that has yet to be built. Construction has been postponed 
indefinitely, because neither of the two contractors has set a date for initial 
delivery of SWP water. 



61 



Urban Uses 

The urban areas served by the State 
Water Project include the most heavily 
populated parts of the most populous 
state in the United States, a state 
whose economy would rank seventh among 
nations of the world. The State Water 
Project is a major water supplier for 
the State's south coastal area, in v^ich 
a little over half of all Californians 
live. In 1975 this area relied on the 
State Water Project for 15 percent of 
its water requirement of 3.4 million 
acre-feet. By the year 2000, this fast- 
growing area is expected to require more 
than 4 million acre-feet of total water 
supply, with the State Water Project 
expected to supply about a third /15/ . 
In the San Francisco Bay area, the 
State's other major population center, 
the State Water Project supplies a 
lesser but still crucial portion of the 
area's total. 



be operated to meet the Tracy standards 
and the State Water Project would pro- 
vide all the additional water necessary 
to meet the standards of Exhibit A or 
Decision 1485. Making up the CVP share 
of the difference in Delta outflow 
requirements between the two sets of 
standards would cost the SWP the equiv- 
alent of 143,000 acre-feet of firm 
annual yield. No Action Cases A and B 
would not affect the yield of the SWP, 
but adverse water quality impacts would 
be associated with each. With the 
Proposed Action, neither the yield nor 
water quality of the SWP would be 
adversely affected. 



Proposed Action 

The Proposed Action of executing the 
draft Coordinated Operation Agreement 
would have no adverse effects in the SWP 
service areas. 



The estimated values of SWP water to the 
project's urban water users in future 
years (1983 dollars) are: 



Year 

1985 
1990 
1995 
2000 
2010 
2020 
2035 



Dollars per 
Acre-Foot 

107 
368 
377 
480 
630 
630 
630 



These estimates are based on the costs 
of meeting projected SWP urban water 
demands through extraordinary conser- 
vation measures and local supply 
alternatives. 



The main effect of the Proposed Action 
as far as the SWP service areas are 
concerned would be to give better assur- 
ance of the full deliverable yield of 
the project in critical years, without 
the substantial yield reduction that 
might be incurred if the CVP were not 
operated to meet the Exhibit A standards 
(as in No Action, Case C) . Another 
possible effect is that with the Pro- 
posed Action, the Department may be able 
to arrange, with successful public 
negotiations and further environmental 
documentation, to buy water from the CVP 
to augment SWP yield (see "Related 
Actions and Projects" section of this 
chapter). Such a yield augmentation 
could help to alleviate expected water 
shortages . 



Environmental Consequences, 
State Water Project Service Areas 

For the State Water Project service 
areas, the scenario of concern is that 
represented by No Action, Case C; in 
which the Central Valley Project would 



No Action 

The three cases of the No Action alter- 
native will be discussed individually. 

Case A . This is the No Action scenario 
in v*iich both the SWP and CVP are 
operated to meet the Tracy standards in 



62 




12: SWP SERVICE AREAS 
CONTRACTING AGENCIES 







Majcimum 


Loca- 


Contracting Agency 


' Annual 


tion 




Entitlement 


No. 




(acre-feet) (a 




(1) 


(3) 




UPPER FEATHER AREA 




1 


City of Yuba City 


9,600 




County of Butte 


27,500 


3 


Plumas County Flood Control and 






Water Conservation District 


2,700 




Subtotal 


39,800 




NOBTri BAY ABEA 




U 


Napa County Flood Control and 






Water Conservation District 


25,000 


5 


Solano County Flood Control and 






Water Conservation District 


i*2,000 




Subtotal 


67,000 




SOUTH BAY AREA 




e 


Alameda County Flood Controj. and 






Water Conservation Dist., Zone 7 




T 


Alameda County Water District 




8 


Santa Clara Valley Water District 


100,000 




Subtotal 


188,000 




SAH JOAQUIN VALLEY AREA 




9 


County of Kings 




10 


Devil's Den Water District 




11 


Dudley Ridge Water District 




12 


Einpire West Side Irrigation 






District 


3,000 


13 


Kern County Water Agency 


l,i53.i*00 


li. 


Oak Flat Water District 


5,700 


15 


Tulare Lake Basin Water 






Storage District (e 


116.500 




Subtotal 


1,355,000 




CENTRAL COASTAL AREA 




:fc 


San Luis Obispo County Flood 
Control and Water Conser- 






vation District 


25,000 


17 


Santa Barbara County Flood 
Control and Water Conser- 






vation District 


57,700 




Subtotal 


82,700 




SOUTHERN CALIFORNIA AREA 




la 


Antelope Valley-East Kern 






Water Agency 


138,ii0O 


19 


Castaic LaJte Water Agency 


1-1,500 


20 


Coachella Valley Water 






District 


23,100 


21 


Crestline-lAke Arrowhead 






Water Agency 


5,80O 


22 


Desert Water Agency 


38,100 


23 


Littlerock Creek. Irrigation 






District 


2,300 


21. 


Mojave Water Agency 


50,800 


25 


Palmdale Water District 




26 


San Bernardino Valley Municipal ' 






Water District 




27 


San Gabriel Valley Municipal 






Water District 


28,800 


20 


San Gorgonio Pass Water Agency 


17,300 


29 


The Metropolitan Water District 






of Southern California 


2,0U,500 


10 


Ventura Covinty Flood Control 






District 


20,000 




Subtotal 


2,1-97,500 




TOTAL STATE WATER PROJECT 


1^,230,000 



63 



critical years and the Exhibit A 
standards in all other years. With the 
Tracy standards controlling Delta water 
quality, quality of the SWP export water 
taken at Clifton Court Forebay would be 
poorer than it would be with the 
Exhibit A standards controlling (see 
Figures 13 and 14). Even so, quality 
would still be sufficient to meet all 
applicable standards for drinking and 
irrigation water, so no attempt was made 
to quantify impacts. Irrigators might 
have to do some additional leaching of 
salts during the non-irrigation period. 

Case B . This is the No Action scenario 
in which the CVP is operated to meet the 
Tracy standards and the SWP releases the 
same amount of water for the Delta that 
it would with the Proposed Action. 
Yield of the SWP would be unaffected as 
compared to the Proposed Action, and SWP 
export water quality would be intermed- 
iate between that expected with the 
Proposed Action and that expected with 
No Action, Case A. 

Case C . The amount of additional water 
the SWP would have to provide for the 
Delta to meet Exhibit A or Decision 1485 
without help from the CVP would vary 
according to the hydrology of the par- 
ticular critical year. Since the 
operators of the SWP could not know in 
advance which years would be critical, 
they would have to operate the SWP in 
every year in a manner that takes into 
account the possibility that a critical 
year is imminent and the CVP will switch 
to Tracy standards. Therefore, the SWP 
operators would hold back deliveries and 
keep a higher reserve in storage against 
the possibility of a critical year. 
Keeping this additional reserve would 
cost SWP water users 143,000 acre-feet 
of their firm annual water supply. 
Using the water supply values given 
earlier and prorating them according to 
the proportions of agricultural and 
urban users of SWP water, 143,000 acre- 
feet of SWP firm annual supply from 1985 
through 2035 has an annual present value 
(at 8.125 percent) of about $28,000,000 
(1983 dollars). This value represents 



the annual potential loss to SWP water 
users should the scenario of No Action, 
Case C, be realized. 



Affected Environment, 
Central Valley Project Service Areas 

At present, the Bureau of Reclamation 
has contracted to deliver 7.32 million 
acre-feet of Central Valley Project 
water, including the sale of an addi- 
tional 250,000 acre-feet of interim 
water to the Westlands Water District. 
Table 9 lists present CVP contractors 
(except those of the Friant Division, 
operated independent of other CVP facil- 
ities) and their maximum contractual 
entitlements. CVP facilities and 
service areas are shown in Figure 15. 

CVP water supply contracts contain 
buildup provisions identifying periods 
during which the contractors may use 
less than their full entitlements. 
Present deliveries (1980) total about 
6.25 million acre-feet to long-term 
contractors. The Bureau estimates that 
nearly all CVP yield will be under 
contract and fully utilized by the year 
2020. 



Agricultural Uses 

The CVP serves agricultural users 
throughout the Sacramento and San 
Joaquin valleys, the two largest of 
California's six major agricultural 
areas . 

After meeting a demand of about 
2.5 million acre-feet for water rights 
and other authorized purposes, the CVP 
delivered about 3.4 million acre-feet of 
irrigation water to farms in 1978. This 
provided a full or partial irrigation 
supply to about 2.1 million acres that 
produced crops valued at about 
$1,644 million. If all project water 
had been used to provide a full supply 
(rather than a combination of full and 
supplemental service), about 1.3 million 
acres could have been irrigated. 



64 



FIGURE 13 

INCREMENTAL BENEFITS IN TDS AT CLIFTON COURT 

PROPOSED ACTION VS NO ACTION - CASE A 



100 



a. 

0. 



00 

Q 




JAN FEB MAR 



APR MAY JUN JUL AUG SEP 
AVERAGE OF CRITICAL YEARS 



OCT NOV DEC 



FIGURE 14 

INCREMENTAL BENEFITS IN CHLORIDES AT CLIFTON COURT 

PROPOSED ACTION VS NO ACTION - CASE A 



100 



2 
a. 

Q- 



Q 

O 

_l 
I 
O 




JAN FEB MAR 



APR MAY JUN JUL AUG 
AVERAGE OF CRITICAL YEARS 



SEP OCT NOV DEC 



65 



Urban Uses 

About 152,000 acre-feet of CVP water was 
furnished to communities for municipal 
and industrial use in 1978. The largest 
share of the water was delivered through 
the Contra Costa Canal to the cities of 
Martinez, Antioch, and Pittsburg and to 
a large industrial complex composed of 



steel, oil, rubber, paper, and chemical 
plants. The cities of Redding, Rose- 
ville, Placerville, Sacramento, Fresno, 
and Coalinga also receive all or a por- 
tion of their water from the CVP. East 
Bay Municipal Utility District and 
Sacramento Municipal Utility District 
have entered into long-term contracts 
for CVP water. 



Table 9 
CENTRAL VALLEY PROJECT LONG-TERM OBLIGATIONS* 



SACRAMENTO VALLEY 



Haxlauai 
Entltleaent 

(acre-Feet ) 



DELTA 



Haxii 
Entitlercnt 

(acre-feet ) 



Clear Creek South 

Cow Creek South 

City of Redding 

Feather Water District 

Spring Creek Conduit aiid Others 

Toyon Pipeline 

Shasta Area 

Sacramento River Diverters: 

Project Water 

Base Supply 

Bypasses and Riparian 
Sacramento Canals: 

Corning Canal 

Tehama-Colusa Canal 

Stony Creek 

Losses 

Subtotal 



AMERICAN RIVER 

El Dorado County 

El Dorado County Water Rights 

Sail Juan Suburban 

City of Rosovil le 

North Fork, Natomas Ditch, Folsom Prison 

Placer County 

City of Sacramento 

Folsom South Canal: 

Sacramento Municipal Utility District 
East Bay Municipal Utility District 
tosses 

Subtotal 



15,500 


Delta-Mendota Canal : 




24,000 


DMC Marketing Program 


537,092 


6,140 


Exchange Contracts 


840,000 


20,000 


Schedule 11 


37,277 


1,500 


Grasslands 


50,000 


3,960 


State of California 


19,000 


5,000 


Losses 


120,000 


374,335 


Contra Costa Canal: 




1,818,416 


Schedule A 


86,000 


500, 000 


Schedule B 


39,000 




Schedule C 


70,000 


43,800 






286,200 


San tuis Canal : 




170 


San tuis Irrigation** 


979,200 


12,000 


San tuis Interim 


7,000 




Miscellaneous 


5,700 


3,110,821 


Municipal and Industrial 


16,500 




tosses 


59,000 




San Felipe Unit 


196,300 




Cross Valley Canal 


125,832 


6,166 






103,834 


Subtotal 


3,187,901 


1 1 , 200 






32,000 






69,000 


TOTAL 


7,132,922 



117,000 
230,000 

75,000 

150,000 

40,000 

834,200 



* Pages C-77 and C-78, Draft Environmental Statement on the Reauthorization of the CVP and the 

Coordinated Operation Agreement for CVP-SWP. 
•* Westlands Water District = 900,000 acre-feet. 



66 



TRINITY RIVER 



Figure 15: THE CVP 

r CLAIR ENGLE LAKE 

msui^KE i AND ITS SERVICE AREAS 

(Service Areas Shaded) 



WHISKEYTOWN RES 

CORNING CANAL 



SACRAMENTO RIVER 



TEHAMA-COLUSA CANAL 




CONTRA COSTA CANAL 



SAN LUIS RES. 



DELTA-MENDOTA CANAL 



^ AUBURN RES. 

t^^^lUMOCO cohstructiom) 

.iL ^FOLSOM LAKE 

folsom souVhj:anal 

l^^ Sacramento -Son^Jooquin Delta 
NEW MELONES RES. 

SAN JOAQUIN hiVER 

^-MADERA CANAL N^ 
'^—UlLLERTON LAKE **>. 

SAN LUIS CANAL **v 

FRIANT-KERN CANAL 







\ 



( 

j 

I 
\ 



67 



Economic and Social Conditions 

The development and growth of the CVP 
has stimulated economic and social 
growth throughout California's Central 
Valley — especially in the San Joaquin 
Valley. Communities have developed in 
some of the new farming areas, and the 
activities within these communities are 
dominated by farming operations. Sev- 
eral San Joaquin Valley counties are 
among the top counties in the nation in 
value of farm products, due to farming 
operations made possible by CVP and 
other water supplies. 

Californians spend millions of "recrea- 
tion days" each year enjoying the boat- 
ing, fishing, swimming, picnicking, and 
other outdoor recreation opportunities 
afforded by CVP facilities. 



Environmental Consequences, 
Central Valley Project Service Areas 

For CVP water users, the choice between 
the Proposed Action of executing the 
draft Coordinated Operation Agreement 
and No Action is between committing the 
water necessary to meet the CVP share of 
Exhibit A requirements or leaving the 
same water uncommitted and possibly 
available for some other use. 

Under the assumptions contained in the 
operation studies supporting the draft 
Agreement, the Bureau of Reclamation 
would be able to meet all of its present 
contractual commitments of about 
7.3 million acre-feet of water, market 
an additional 900,000 acre-feet, and 
meet its share of Exhibit A along with 
the SWP. 

Theoretically, there are two conditions 
when CVP water users could expect to 
take larger than normal deficiencies as 
a result of the Proposed Action: during 
critically dry years, and at the 
ultimate level of CVP development . 
However, if in the No Action cases the 
water needed to meet the CVP share of 
the Exhibit A requirements were reserved 



to supply new contractors, the 
consequences for the existing CVP 
contractors would be the same as with 
the Proposed Action. 



Affected Environment, 
Rivers and Reservoirs 

This section describes the resources 
potentially affected by the Proposed 
Action and the No Action alternative in 
and on the river systems controlled by 
the CVP and SWP. The CVP controls the 
Trinity, Sacramento, and American 
rivers ; the SWP controls the Feather and 
(with the CVP) the Sacramento below its 
confluence with the Feather. 



Sacramento River 

California's largest river, the 
Sacramento, drains the northern half 
of the Central Valley basin, including 
the Sacramento Valley. The headwaters 
are in the Cascade Mountains, although a 
major tributary, the Pit River, 
originates in the Goose Lake basin on 
the California-Oregon border. The 
drainage area of the Sacramento River 
above Shasta Dam encompasses 
6,649 square miles, producing a mean 
unimpaired annual flow of 5 . 7 million 
acre-feet (1894-95 through 1946-47). 
The portion of the Sacramento most 
susceptible to being affected by the 
Proposed Action or its alternative is 
the reach from Shasta Dam to Red Bluff 
Diversion Dam, but effects are possible 
along the full length of the river from 
Shasta Dam through the Sacramento- 
San Joaquin Delta. 

Project Facilities . Shasta Dam, on the 
Sacramento River, 9 miles northwest of 
Redding, is the key facility of the CVP. 
It impounds Shasta Lake, with a maximum 
capacity of 4.5 million acre-feet. The 
lake is popular for boating, fishing, 
swimming, water-skiing, camping, 
hunting, and houseboating. Recreation 
use is about 2 million visitor days 
annually. The fishery is moderately 



68 



productive for both warmwater and 
coldwater species. 

Keswick Dam, 9 miles downstream from 
Shasta Dam, forms Keswick Reservoir as 
an afterbay for Shasta Dam. Keswick has 
fish trapping facilities that operate in 
conjunction with the Coleman Fish 
Hatchery, 25 miles downstream on Battle 
Creek. Salmon and other fish are 
trapped as they reach the dam, and are 
then taken to the hatchery, operated by 
the U. S. Fish and Wildlife Service. 

About 50 miles downstream from Keswick 
Dam, the CVP operates Red Bluff 
Diversion Dam to channel Sacramento 
River water into the Corning and Tehama- 
Colusa canals. Together, the canals can 
divert as much as 3,030 cfs to 
agricultural areas on the west side of 
the Sacramento Valley. The first reach 
of the Tehama-Colusa Canal has the 
additional function of providing 
1.6 million square feet of gravel bottom 
for salmon spawning. This is the 
world's largest spawning facility. 

Seepage. Seepage through the levees and 
onto adjacent farmlands can become a 
problem along the middle and lower 
reaches of the Sacramento River during 
high flow periods. In some instances, 
seepage damage to orchard and field 
crops has been estimated in the millions 
of dollars. 

The critical stages that will cause 
seepage vary along the river and are not 
precisely known. For this report, it 
was assumed that a potential for seepage 
problems exists when flows below Red 
Bluff Diversion Dam exceed 1 million 
acre-feet per month, which is consistent 
with observed occurrences of seepage. 

Water Quality . Two water quality 
problems affecting the Sacramento River 
are high water temperatures and heavy 
metal toxicity. Warm water temperatures 
in the upper reaches of the river some- 
times adversely affect upstream salmon 
migration and spawning. This problem is 



most severe in the early fall of dry 
years when low flows of relatively warm 
water are further influenced by high 
ambient air temperatures. The heavy 
metal toxicity problem stems from high 
levels of copper, zinc, and other 
metallic ions in Spring Creek, viiich 
discharges into Keswick Reservoir. The 
metals originate from several inactive 
mines in the Spring Creek basin. During 
heavy runoff periods, v^en Spring Creek 
Reservoir spills, heavy metal concentra- 
tions can become high enough to kill 
fish in Keswick Reservoir and the 
Sacramento River . 

Fishery Resource . Eight species of 
anadromous fish and over 60 species of 
resident fish are found in the 
Sacramento River. The major anadromous 
species are chinook salmon, steelhead 
trout, striped bass, American shad, and 
white sturgeon. Only chinook salmon and 
steelhead trout run upstream from the 
Red Bluff Diversion Dam in significant 
numbers. These fish occur throughout 
the main stem of the river and in 
accessible reaches of tributary 
streams . 

Four runs or races of chinook salmon 
occur in the Sacramento River and its 
tributaries. These are the fall, late 
fall, winter, and spring runs. Each run 
is a genetically distinct race that 
migrates into the river and reproduces 
within a specific time period and 
location. Collectively, they comprise 
the primary source of chinook salmon 
caught in California's ocean. They also 
contribute significantly to the ocean 
fisheries of Oregon and Washington. 
Because of the different migration and 
spawning periods of these runs, salmon 
at various life stages are found in the 
mainstream Sacramento River during every 
month of the year. These life stages 
may consist of the adult fish, incubat- 
ing eggs, developing alevins or sac fry, 
emergent fry, fingerlings, and subyear- 
ling juveniles. The name of each run 
generally denotes when adult spawners 
begin to migrate into the river. 



69 



From 1971 to 1982, all chinook salmon 
runs in the Sacramento River and tribu- 
taries upstream from the mouth of the 
Feather River averaged an estimated 
136,000 annually (Table 10). The fall 
run is the largest and most widely 
distributed; the winter run is the next 
largest. The estimated average annual 
net economic (business related) value of 
all the runs to the commercial and sport 
fisheries is about $20 million, and 
somewhat higher based on willingness to 
pay. 

The various runs have different prefer- 
ences regarding spawning areas, but all 
spawn either in the main stem of the 
Sacramento River in the 100-mile reach 
between Hamilton City and Keswick Dam, 
or in tributaries to this reach. Major 
changes have occurred in the distribu- 



tion of fall run spawning stocks in the 
main stem Sacramento River during the 
past 25 years. The most evident trend 
has been a reduction in spawning popu- 
lations above Red Bluff Diversion Dara 
and a significant, but lesser, increase 
below the dara. Late fall and winter run 
salmon spawning also has declined above 
Red Bluff Diversion Dara in recent 
years . 

Steelhead trout, a prized sport fish, 
spawn in the upper reaches of tributary 
streams \^ere year-round cold water 
occurs. Very few, if any, spawn in the 
main stem of the Sacraraento River. The 
average number of steelhead counted 
annually at Red Bluff Diversion Dam for 
1966 through 1982 was about 7,000, but 
less than 3,000 were counted each year 
from 1980 through 1982. 



Table 10 

CHINOOK SALMON SPAWNING STOCKS IN THE SACRAMENTO RIVER SYSTEM 

(in Thousands of Fish) 





Sac 


r amenta 


River 


Systen 




Sacranento River 






Above 


Red Bluff 


Battle 


Mainatreaa ^ 




(Excluding 


Battle Creek) 


Creek ^ 


Below 


Red Bluff^ 






Late 












Year 


Fall 


Fall 


Hintei 


Spring 


Fall 




Fall 


1971 


59 


17 


53 


6 


5 




23 


1972 


36 


33 


28 


7 


5 




15 


1973 


44 


22 


23 


7 


8 




17 


1974 


49 


6 


19 


4 


4 




28 


1973 


53 


18 


23 


10 


5 




36 


1976 


57 


16 


33 


25 


5 




36 


1977 


40 "* 


9 


16 


13 


— 




46 


1978 


35 


12 


25 


6 


4 




48 


1979 


48 


10 


2 


3 


15 




67 


1980 


22 


9 


1 


9 


14 




30 


1981 


29 


7 


20 


21 


17 




43 


1982 


19 


5 


1 


23 


27 




24 



Other 
Tributaries^ 

All Combined 

5 
3 

6 

8 
15 

1 
3 
3 
2 
2 

10 
9 



Total 

Sacraawnto River Syste 

Above Feather River 



Fall 


All Runs 


87 


168 


56 


127 


69 


127 


81 


126 


96 


162 


98 


173 


88 


127 


87 


133 


130 


145 


67 


87 


92 


147 


70 


108 



Average 41 



13 



20 



11 



35 



85 



136 



1 Includes spawners collected for Coleman Fish Hatchery. 

2 No estimates for races other than fall run chinook salmon. 

3 Includes minor streams that a few hundred salmon enter regularly, 
'♦Includes Battle Creek. 

Source: California Department of Kish and Game. 



70 



Rare, Threatened, and Endangered 
Species . Six rare, threatened, or 
endangered animal species occur in or 
near the Sacramento River and Shasta 
Lake (see Table 6). Four rare or 
endangered plant species also occur here 
(see Table 7) . 



Trinity River 

The Trinity River drains a mountainous 
watershed of 2,846 square miles in 
northwestern California. This is an 
area of high precipitation, which gives 
the river a mean unimpaired annual flow 
volume of nearly 4 million acre-feet 
(1894-95 through 1946-47) near its 
confluence with the Klamath River. The 
reach of the Trinity potentially 
affected by the Proposed Action or No 
Action is the 40 miles downstream from 
Lewiston Dam to the confluence with the 
North Fork Trinity River. 

Project Facilities . The Trinity River 
Division of the CVP includes two dams on 
the Trinity River: Trinity Dam, v^ich 
impounds Clair Engle Lake ; and Lewiston 
Dam, which impounds Lewiston Lake. Mean 
unimpaired annual flow volume above 
Lewiston is 1,26 million acre-feet 
(1894-95 through 1970-71). Clair Engle 
Lake has a storage capacity of 
2,448,000 acre-feet. Lewiston Lake, 
7 miles downstream, creates an afterbay 
for Trinity Dam and allows diversion 
into the 10.7-mile Clear Creek Tunnel, 
which conveys Trinity River water to 
Judge Francis Carr Powerplant and 
Whiskey town Lake, in the drainage of the 
Sacramento River. 

Clair Engle Lake offers recreation 
opportunities in the form of camping, 
boating, water-skiing, swimming, 
fishing, and hunting. Recreation use 
was 600,000 visitor days in 1978, down 
from 2 million in 1975. With water low 
in nutrients, Clair Engle Lake is not 
considered highly productive, yet it 
supports both warmwater and coldwater 
fish populations. 



Fishery Resource . The reach below 
Lewiston Dam provides spawning and 
rearing habitat for fall run and spring 
run Chinook salmon, coho salmon, steel- 
head trout, and some resident trout. 
This reach is the major spawning area 
for fall run chinook salmon in the 
entire Trinity River drainage. 

Trinity River Fish Hatchery, built by 
the Federal Government as a mitigation 
feature of the Trinity River Division, 
CVP, is located immediately below 
Lewiston Dam and raises fall run and 
spring run chinook salmon, coho salmon, 
and steelhead trout . 

The fishery supported by the river and 
hatchery contributes to the major sport 
and Indian fisheries of the more exten- 
sive Trinity/Klamath system and to the 
associated sport and commercial fishery 
in the Pacific Ocean. 

Upriver fishery resources have been 
negatively impacted by the Trinity 
project, land use practices, timber 
harvest, road construction, and fishing. 
So far, mitigation measures have been 
largely ineffective at maintaining 
preproject levels of fish. Recently, 
some recommendations of the Trinity 
River Fish and Wildlife Task Force have 
been implemented by restoring gravel 
spawning beds, removing sand, and 
increasing flows below Lewiston Dam. 
Releases from the dam since 1980 have 
been 285,000 acre-feet annually — more 
than double the previous minimum 
releases — plus additional releases for 
flood management . The Task Force 
recommended a more extensive long-term 
fish habitat and hatchery program. 
Congress authorized and funded the 
Trinity River Basin Fish and Wildlife 
Restoration Program. 

Rare, Threatened, and Endangered 
Species . The bald eagle occurs near 
Whiskeytown Reservoir and Clair Engle 
Lake, as indicated in Table 6. 



71 



Feather River 

The Feather River is a major tributary, 
joining the Sacramento River near 
Verona, 21 river miles above Sacramento. 
Above Oroviile Dam, the Feather River 
drains 3,634 square miles of watershed 
with an average annual runoff over the 
past 80 years of 4.2 million acre-feet. 
Below Oroviile Dam, an additional 2,297 
square miles of watershed contributes 
1.5 million acre-feet annually, prin- 
cipally by two large tributaries, the 
Yuba River and the Bear River. The 
reach of the Feather River potentially 
affected by the Proposed Action or No 
Action is the 45-mile reach between 
Oroviile Dara and the confluence with the 
Sacramento River. 

Project Facilities. The northernmost 
features of the State Water Project are 
located on the Feather River and its 
tributaries. Three reservoirs on upper 
tributaries — Frenchman Lake, Antelope 
Lake, and Lake Davis — have a combined 
storage capacity of 162,414 acre-feet 
and provide for local irrigation, 
recreation, and incidental flood 
control. 

Lake Oroviile, impounded behind Oroviile 
Dara on the main stem of the Feather, is 
the key storage facility of the SWF. 
The lake has a capacity of about 
3.5 million acre-feet, a maximum surface 
area of nearly 16,000 acres, and a 
shoreline of up to 167 miles. 

Normal releases from Lake Oroviile are 
made through the intake to the Edward 
Hyatt Powerplant. The intake structure 
is designed so it can draw from various 
depths in the reservoir pool, thus 
allowing adjustments in the temperature 
of the release water. 

After going through the power plant, the 
water enters Thermalito Diversion Pool, 
created by Tliermalito Diversion Dam, 
Certain fish maintenance flows are 
released directly from this dara to the 
river, but greater voluraes are diverted 
to two irrigation canals, the Feather 



River Fish Hatchery, and Thermalito 
Powerplant. Four canals divert from the 
afterbay of Thermalito Powerplant. 
Return flows from the fish hatchery and 
Thermalito Afterbay rejoin the river. 

The Oroville-Thermalito complex controls 
potential floodwaters, conserves water 
for release downstream, stores water for 
power generation, and provides recrea- 
tion opportunities. Recreation use at 
Lake Oroviile peaked at 800,000 visitor 
days in 1981. The lake supports consid- 
erable warmwater and coldwater fish 
populations . 

Fishery Resource . Construction of 
Oroviile Dara elirainated spawning areas 
for salmon and steelhead upstream of the 
dam. To compensate for this loss, the 
Department of Water Resources built the 
Feather River Fish Hatchery downstream 
of Oroviile Dam on the northern bank of 
the Feather River. Feather River Fish 
Barrier Dam, 1/2 mile downstream of 
Thermalito Diversion Dam, diverts 
migrating salmon and steelhead into the 
Feather River Fish Hatchery. Here, a 
large number of adult fish can be 
trapped, held, and artifically spawned, 
or moved into the spawning channel . 

Most of the 40-mile reach of the Feather 
River below the Fish Barrier Dam is 
available for natural spawning. Minimura 
flows are maintained in the 5-mile "low 
flow section" between the Fish Barrier 
Dam and the river outlet from Thermalito 
Afterbay. About 80 percent of the 
natural spawning occurs within this 
reach. 

The 36-mile reach of the Feather River 
below the Thermalito Afterbay river out- 
let, known as the "high flow section", 
receives a minimum flow of about 1,700 
cfs and accommodates about 20 percent of 
the naturally spawning salmon — all 
within the upper half of this reach. 
The entire 40-mile reach below the Fish 
Barrier Dara is used for juvenile salmon 
rearing. Spawning escapement totals 
about 50,000 chinook salmon, mostly fall 
run with some spring run, of which from 



72 



3,000 to 5,000 enter the hatchery. 
Other species include American shad, 
striped bass, steelhead trout, and many 
resident warmwater and coldwater 
species . 

Rare, Threatened, and Endangered 
Species . Five rare, threatened, or 
endangered animal species occur near the 
Feather River and Oroville Lake (see 
Table 6). 



American River 

The American River drains a 1,921- 
square-mile area in the north-central 
portion of the Sierra Nevada. With mean 
annual unimpaired runoff estimated at 
2.6 million acre-feet (at Fair Oaks, 
1894-95 through 1970-71), the American 
River is a major tributary to the 
Sacramento River. The section of the 
American that might be affected by the 
Proposed Action or No Action is the 
25 miles between Nimbus Dam and the 
mouth. This entire reach is within the 
Sacramento metropolitan area. 

Project Facilities . CVP facilities on 
the American River include Folsom Dam 
and Reservoir, with 1,010,000 acre-feet 
of storage capacity, and Nimbus Dam, 
which impounds Lake Natoma as an after- 
bay for Folsom Dam. These facilities 
regulate riverflow for irrigation, 
power, flood control, municipal and 
industrial use, and other purposes. 
Folsom Lake is heavily used for recrea- 
tion, with an 18,000-acre park that is 
the most popular unit of the California 
State Park System. Recreation use of 
Folsom Lake and Lake Natoma runs about 
2 million visitor days annually. Fish- 
ing, swimming, and water-skiing are the 
main attractions. 

Fishery Resources. The American River 
and associated backwaters and dredger 
ponds downstream from Nimbus Dam support 
at least 41 species of fish, including 
Chinook salmon, steelhead trout, striped 
bass, and American shad. Operation of 
Folsom and Nimbus dams, which were com- 



pleted in 1955, has favorably affected 
fish populations, particularly of fall 
run Chinook salmon by changing flow 
releases to improve habitat. Improve- 
ment of the fishery can also be attrib- 
uted to successful operation of the 
Nimbus Salmon and Steelhead Hatchery, 
below Nimbus Dam. 

For the period 1969 to 1981 the spawning 
escapement of salmon to the river and 
Nimbus Salmon and Steelhead Hatchery 
averaged 47,500 fish. Of these, about 
60 percent were produced from fish 
spawning naturally in the river and 
40 percent from hatchery operations. 
Steelhead trout escapement, supported 
entirely by the hatchery, runs as high 
as 15,000 to 20,000 annually. Unknown, 
but high, numbers of striped bass and 
American shad also ascend the American 
River and provide good angling. 

Angling for all species in the American 
River totals about 150,000 to 200,000 
angler days annually. Chinook salmon 
from the American support about 60,000 
saltwater angler days and a commercial 
harvest of 985,000 pounds annually. 

Rare, Threatened, and Endangered 
Species. Three rare, threatened, or 
endangered animal species occur near the 
lower American River and Folsom Lake 
(see Table 6). One endangered plant 
species occurs here (see Table 7). 



Environmental Consequences, 
Rivers and Reservoirs 

The Proposed Action and the No Action 
cases could differ in their effects on 
rivers and reservoirs controlled or 
operated by the CVP and SWP. The 
differences would arise in critical 
years. With the Proposed Action, both 
projects would be operated in all years 
to meet the Delta water quality and 
outflow requirements contained in 
Exhibit A of the proposed Coordinated 
Operation Agreement. In the No Action 
cases, it is assumed that in critical 
years the CVP or both the CVP and the 



73 



SWP would be operated for the CVP's 
Tracy standards, which require less 
water to be released from reservoirs 
than do the standards of Exhibit A. 

The analysis in this section is based on 
an assumption that the water the two 
projects could save by meeting the Tracy 
standards instead of the Exhibit A 
standards in critical years would be 
retained in the reservoirs. This 
assumption maximizes the environmental 
differences between alternatives, but it 
is realistic only to the extent that 
retaining the saved water in the 
reservoirs would be one option for the 
projects. Another option would be 
releasing the saved water for delivery 
to project contractors to reduce the 
severity of deficiencies the contractors 
would be taking in critical years. The 
likelihood that the saved water would be 
delivered rather than retained increases 
with time; i.e., is greater at the 2020 
level of development. To the extent 
that any water saved by operating for 
the Tracy standards rather than for the 
Exhibit A standards would be released 
instead of retained in the reservoirs, 
the environmental consequences of No 
Action would approach those of the 
Proposed Action as far as rivers and 
reservoirs are concerned. 



Proposed Action 

In critical years, the Proposed Action 
would place greater demands on CVP 
reservoirs than would necessarily exist 
in any No Action case. The Proposed 
Action would also place greater 
critical-year demands on the SWP ' s 
Oroville Reservoir than would exist in 
No Action, Case A. 

Sacramento River and Shasta Lake . 
Operation studies comparing the Proposed 
Action to the No Action cases indicate 
slightly increased spring flows, 
occasional flow reductions during high 
release periods, and lower Shasta Lake 
levels during critical years with the 
Proposed Action. 



The lower Shasta Lake levels would cause 
increases in the temperature of water 
released to the upper Sacramento River 
below the dam. Significant temperature 
increases were found for three critical 
years: 1931, 1933, and 1934. The oper- 
ation studies included 83 years, 1895 to 
1977, of which 6 qualified as critical 
by at least one set of critical-year 
criteria. Temperature increases in the 
3 years showing significant increases 
ranged from 1 to 2 degrees Fahrenheit at 
the 1980 level of development and from 
1 to 4 degrees at the 2020 level. 

Table 11 shows projected upper 
Sacramento River temperatures with the 
Proposed Action and with No Action for 
water year 1933, the year of maximum 
temperature differences between Proposed 
Action and No Action. The projected 
temperatures were based on mathematical 
reservoir and river model studies that 
simulated 1933 hydrologic and tempera- 
ture conditions. 

Temperatures exceeding 56''F adversely 
affect the survival of salmon eggs and 
alevins (salmon fry with yolk sac still 
attached) . Water temperatures in excess 
of 60°? also cause advanced maturation 
of female salmon spawners, resulting in 
increased adult prespawning mortality. 
The Department of Fish and Game's esti- 
mates of mortality of chinook salmon 
eggs and fry at 1 °F increments of temp- 
erature increase above 56 °F are shown 
below. 



Incubation 




Temperature 


Mortality 


Cf) 


(Z) 


56 


8 


57 


10 


58 


13 


59 


30 


60 


50* 


61 


80 


62 


100 


*No Data 





74 



T^le 11 

POTENTIAL TEMPERATURE IMPACTS OF THE PROPOSED ACTION IN A CRITICALLY DRY YEAR (1933) 

(Estiraatod Moai Monthly Temperatures in Degrees Fahrenheit) 



Location and Criteria* 

Sacramento River at Keswick 
Proposed Action 
No Action 
Increase With 
Proposed Action 

jdcramorito River at Cottonwood 
Proposed Action 
No Action 
Increase With 
Proposed Action 



1980 Level of Development 



2020 Level of Development 



May Jun Jul Aug Sep Oct Nov May Jun Jul Aug Sep Oct Nov 



47 


49 


53 


56 


58 


57 


54 


47 


48 


52 


55 


57 


56 


54 



48 52 59 62 62 59 56 
47 50 55 58 60 58 56 



51 


53 


59 


60 


60 


57 


53 


53 


56 


62 


63 


63 


59 


55 


51 


53 


58 


59 


59 


57 


53 


53 


55 


59 


61 


61 


58 


55 



Sacramento River at Red Bl 


off 






























Proposed Action 




53 


55 


61 


61 


61 


57 


52 


55 


57 


64 


64 


63 


59 


54 


No Action 




53 


55 


60 


60 


60 


57 


52 


55 


56 


62 


62 


62 


58 


54 


Increase With 
































Proposed Action 










1 


1 


1 











1 


2 


2 


1 


1 






Trinity River at Lewiston** 
Proposed Action 
No Action 
Increase With 
Proposed Action 



53 

52 



62 
59 



61 
57 



49 
49 



49 
48 



46 
46 



American River at Nimbus 






















Proposed Action 


61 


65 


- 71 


- 62 


- 


64 


68 


- 72 


- 62 


_ 


No Action 


60 


64 


71 


- 61 


- 


64 


68 


72 


- 62 


_ 


Increase With 






















Proposed Action 


1 


1 





1 


- 














- 



♦ No Action refers to all cases of that alternative. 
••Evaluated for 1932; impacts less in 1933. 
- Not Evaluated . 



Considered on a worst-case basis (i.e., 
hydrology of critical year 1933 and 
maximum possible differences in storage 
levels at Shasta Lake), the Proposed 
Action would result in water temperature 
increases (compared to No Action) that 
would adversely affect winter run salmon 
eggs and alevins during the incubation 
and development period from July through 
September. These increases would be 
incremental to background temperatures 
that have reached or exceeded the maxi- 
mum desired temperature of 56°F. At the 
1980 operational level, incremental 



mortality attributable to the Proposed 
Action would range from 2 to 20 percent 
because of a 1- to 2-degree increase in 
mean monthly river temperature (see 
Table 12). The impacts would primarily 
occur to: 

The late spawning segment of the run 
(with resulting pre-emergent fry still 
in the gravels during September), and 

That portion of the run spawning in 
the river reach near Red Bluff. 



75 



Table 12 

ESTIMATED SACRAMENTO RIVER MEAN MONTHLY TEMPERATURE INCREASE AND 

CORRESPONDING INCREASE IN MORTALITY OF CHINOOK SALMON EGGS AND FRY 

POTENTIALLY RESULTING FROM T* PROPOSED ACTION* 



Level of 
Development 

1980 



2020 



June 



Location 

Keswick 
Cottonwood 
Red Bluff 

Keswick 
Cottonwood 
Rod Bluff 







N/C 
N/C 

2 
1 8 
1 2 



July 




17 
30 



4 50 
3 70»» 
2 0»» 



August 
•F S 



Sept. 
"F 



Oct. 



Nov. 



1 8 

1 20 

1 30 

4 87 »♦ 

2 20»» 
2 0»* 



1 3 

1 20 

1 30 

2 50 *» 
2 20»* 
1 0** 



1 2 

N/C 
N/C 



1 



17 
17 
17 



•F 



N/C 
N/C 
N/C 

N/C 
N/C 
N/C 



* Base level is that of No Action (same for Cases A, B, and C). 
** Total mortality will be 100 percent. 

N/C z No Change 



At the 2020 operational level, again in 
worst-case (1933) conditions, incre- 
mental mortality of winter-run salmon 
with the Proposed Action would range 
from 13 to 70 percent, because of a 2- 
to 4-degree increase in background mean 
monthly temperature that would already 
exceed 56°F. Essentially, the only 
winter run salmon spawning and incuba- 
tion habitat remaining in the Sacramento 
River under these conditions with the 
Proposed Action at 2020 levels would be 
for early spawning segments immediately 
below Keswick Dam. Even then, an August 
mean temperature of 60°F (4°F induced by 
the Proposed Action) would result in 
50 percent mortality of winter-run 
salmon eggs and alevins. 

Temperature increases attributable to 
the Proposed Action under worst-case 
(1933) conditions would also adversely 
affect spring-run chinook salmon in the 
main stem of the Sacramento River. The 
major impact at the 1980 level would be 
on September spawners, which would 
suffer a 10 to 20 percent reduction in 
egg survival (see Table 12). Spring-run 
spawning at Red Bluff would be elimi- 
nated in September because of high water 
temperature (62°F). At the 2020 level, 
the mean October river temperature for 
worst-case (1933) conditions is pro- 
jected at 61 °F as far downstream as Red 



Bluff. This condition would be expected 
to result in incremental mortality of 
17 percent and a total mortality of 
30 percent. 

Fall-run chinook salmon would be 
impacted only slightly by worst-case 
conditions with the Proposed Action at 
the 1980 operating levels (2 percent 
incremental mortality in October of eggs 
deposited downstream of Keswick; see 
Table 12). However, at the 2020 
operational level, fall run spawning 
success during critically dry years 
would be reduced more significantly. 
Mean monthly temperature increases of 
1 °F would result in 59 °F temperatures as 
far downstream as Red Bluff during 
October, resulting in loss of 17 percent 
of eggs deposited during this period. 
There would be no impact in November. 

Although Table 12 shows potential 
mortality impacts, it does not quantify 
actual impacts on the salmon runs. In 
other words, an impact of 100 percent in 
a certain month may not be significant 
if few salmon are present at that time 
or location. To better assess salmon 
impacts, a mathematical model was used 
to estimate overall temperature-related 
mortalities. The model computes salmon 
losses from daily river temperatures 
based on historical distributions of 



76 



runs by river location and time of year. 
The temperature-mortality criteria 
listed above were used, along with 
criteria for fingerlings. 

Table 13 shows model estimates of salmon 
run losses for 1933. As discussed 
above, the major impact is on the winter 
run because of the high summer river 
temperatures. The impacts on all runs 
combined, however, are only 4 percent at 
1980 level and 8 percent at 2020, since 
impacts on the major fall run are 
relatively small. 

Temperature impacts indicated for water 
years 1931 and 1934 were similar to 
1933. In other critical years, the 
indicated temperature differences 
between the Proposed Action and No 
Action were too small to be meaningful, 
considering the accuracy of the model. 

Regarding predicted thermal impacts to 
salmon, it should be recognized that 
these projections are based on less than 
4 percent frequency of occurrence (3 
years in 83) and that these effects may 
not occur under a different set of 
operating assumptions. Inherent in this 
Agreement is the commitment by both the 
CVP and SWP to meet adopted standards 
designed to protect this resource. 



Coordinating operations of both protects 
to meet these standards is judged more 
beneficial to salmon overall than if 
these standards are not met. 

Lower storage in Shasta Lake during the 
late fall and winter of critical years 
would provide less dilution capability 
for control of toxic metal discharges 
from the Spring Creek drainage. Higher 
Sacramento River flows with the Proposed 
Action would tend to offset this impact, 
however. Possible impacts on toxic 
metal concentrations and fish in the 
Sacramento River have not been quanti- 
fied, but are not expected to be 
significant . 

Any impacts on steelhead trout that 
might result from the Proposed Action's 
effects on Sacramento River flow and 
temperature would probably be minimal . 
Steelhead trout spawn primarily in the 
upper accessible reaches of tributary 
streams, and their spawning would there- 
fore not be impacted by environmental 
changes in the main stem of the 
Sacramento River. 

Operation studies were reviewed for 
potential seepage problems with the 
Proposed Action and no significant 
effects were found. 



Table 13 
SACRAMENTO RIVER TEMPERATURE -REUTED SALMON LOSSES — 1933 (CRITICAL YEAR) 



Level oF 
Development 

1980 



2020 



Salwon Run Loss (Percent) 



Criteria 



Proposed Action 

Nto Action 

Increase With Proposed Action 

Proposed Action 

No Action 

Increase With Proposed Action 











All* 


Fall 


Late-Fall 
25 


Winter 
25 


Spring 
41 


Runs 


37 


34 


35 


20 


18 


35 


30 


2 


5 


7 


6 


4 


40 


42 


65 


56 


46 


37 


33 


40 


54 


38 


3 


9 


25 


2 


8 



♦ Weighted by historical salmon run size: (Fall 61. ASS; Late-Fall 12.6SS; Winter 18.155; Spring 1.9%). 



77 



The lower storage levels in Shasta Lake 
would be expected to cause slight, but 
not significant adverse impacts on resi- 
dent fish in that lake and on recreation 
use (see CEQA criteria in Appendix K). 
Table 14 shows recreation impacts. The 
reduction in average annual recreation 
use with the Proposed Action was esti- 
mated at less than one percent at both 
the 1980 and 2020 development levels. 

Effects of Changing Annual Drawdowns 
to Cultural Resources. Increased 
drawdowns may adversely affect cultural 
resources in the drawdown zone by 
erosion and exposure to vandals. The 
expected impacts, by reservoir, are: 

Shasta — By year 2020, a 4 percent 
increase of drawdowns of more than 
100 feet is expected with the Agree- 
ment (Table 14). This will slightly 
increase erosion of cultural resources 
and their exposure to vandalism. If 
such a scenario does occur, the U. S. 
Forest Service and the Bureau of 
Reclamation will account for this 
potential in future cultural resources 
planning, with concurrence of the 
State Historic Preservation Officer. 

Clair Engle -- No changes in drawdown 
frequency are expected. 

Whiskeytown -- Less fluctuation in 
reservoir levels will occur. This 
should benefit those cultural 
resources in the drawdown zone . 

Rare, Threatened, and Endangered 
Species. Nesting and wintering bald 
eagles at Shasta Lake or the Sacramento 
River would not be affected by the 
Proposed Action. Lower water levels in 
Shasta Lake could slightly reduce the 
numbers of warrawater fish, but avail- 
ability of fish as food for eagles might 
actually improve. The extreme drawdown 
of Shasta Lake during the 1977 drought 
increased bald eagle productivity, prob- 
ably because fish were concentrated in a 
smaller volume of water and sediment 
beds were exposed on tributary streams. 



This allowed the eagles to easily spot 
dead or dying fish. 

The Proposed Action would not affect 
Shasta salamander populations because 
the level of the lake would not 
increase. Neither would the Proposed 
Action affect the giant garter snake, 
Swainson hawk, peregrine falcon, 
California yellow-billed cuckoo, valley 
sagittaria, slender orcutt grass, 
greene's orcutt grass, or hairy orcutt 
grass. These species inhabit areas near 
the Sacramento River. They would not be 
impacted because the flow of the Sacra- 
mento River would not significantly 
change and, therefore, would not affect 
adjacent habitat. 

Trinity River and Clair Engle Lake . The 
Proposed Action and its No Action alter- 
native (all cases) would be no different 
in regard to flows provided for the 
Trinity River, Because of exports from 
the Trinity River drainage to the 
Central Valley, however, storage levels 
in Clair Engle and Lewiston reservoirs 
could differ between the alternatives, 
and this could cause differences in 
temperature of the release water. 

Temperature differences indicated by 
1980-level and 2020-level operation 
studies comparing the Proposed Action 
and No Action (all cases) are shown in 
Table 11, These differences are based 
on hydrology of the critical year 1932 
and represent the maximum impacts found 
in any of the years studied. Tempera- 
ture differences in spring months were 
considered insignificant. 

Higher water temperatures with the 
Proposed Action in critical years such 
as 1932, as compared to temperatures 
that wDuld exist with the No Action 
alternative, would be harmful to salmon 
in their spawning and incubating stages. 
The temperature increases in October and 
November would be especially harmful and 
could preclude successful hatching of 
fall spawning salmon. The Trinity River 
Fish Hatchery would be affected in the 



78 



same way as the natural spawning areas 
in the river, since its water source is 
the same. The temperature control 
facilities at the hatchery intake at 
Lewiston Dam are now being evaluated and 
may mitigate impacts on the hatchery. 

Salmon impacts as described above may 
not occur under different operating 
assumptions; they represent less than 
4 percent of the years studied as a 
worst case. The greater flexibility 
offered by the proposed action affords a 
greater level of protection to salmon 
resources than has previously existed. 
It is also judged that meeting the 
standards of the proposed action is more 
beneficial to salmon than if these 
standards were not met. 

Water levels in Clair Engle Lake would 
be lower during critical years with the 
Proposed Action, as compared to No 
Action, but not enough to significantly 



impact recreation or resident fish (see 
Table 14). 

The Proposed Action would not affect 
bald eagle populations at Clair Engle 
Lake . 

Feather River and Lake Oroville . 
Operating SWP facilities on the Feather 
River to meet the standards of the 
Proposed Action's Exhibit A rather than 
the Tracy standards applicable in No 
Action, Case A, would cause increased 
drawdown at Oroville Reservoir and 
flow-related effects in the Feather 
River. Temperature-related effects 
would not be significant. 

Operation studies indicate that differ- 
ences between the Proposed Action and No 
Action, Case A, would be limited almost 
exclusively to critical years and the 
year immediately following. 



Table 14 

ANNUAL DRAWDOMN AND RECREATICM VISITS AT SELECTED CVP RESERVOIRS 

WITH AND WITHOUT COORDINATED OPERATION AGREEMENT 

(1980 and 2020 Level of Development) 



Reservoir 



Shasta 



Clair Engle 



Whiskeytown 



Folsom 





»wn« 


Annual 
Recreation 

Visits** 


OptiMun 
DrsMdoMn 
Frequency 


Drawdown 


Freque 




1980 




DraMdc 


Without 


With 


(feet 


) 

20 


(millions) 

A. 9 - 5.3 


(percent ) 

78 


COA 


COA 


- 


16 


16 


20 - 


50 


4.7 - 4.9 


12 


54 


56 


50 - 


70 


4.0 - 4.7 


2 


12 


8 


70 - 


100 


3.3 - 4.0 


6 


11 


11 


Over 


100 


Less Than 3.3 


2 


7 


9 


- 


20 


1.5 


96 


18 


18 


20 - 


45 


1.2 - 1.5 


4 


38 


38 


Over 


45 


Less Thai 1.2 





44 


44 


- 


1 


1.7 


80 


30 


28 


Over 


1 


Less Than 1 . 7 


20 


70 


72 


- 


50 


2.7 - 3.4 


NA 


14 


14 


30 - 


39 


2.2 - 2.7 




19 


19 


Over 


39 


Less Than 2.2 




67 


67 



2020 



Without 


With 


COA 


COA 


29 


29 


29 


28 


17 


17 


19 


16 


6 


10 


74 


74 


16 


16 


10 


10 


99 


99 


1 


1 


5 


5 


18 


18 


77 


77 



» Drawdown = Full pool - August eiid-of-month storage. 

** Recreation visits and drawdown criteria from "CVP Reauthorization", DCS 80-47, 7/29/80. 

»♦* Frequencies from operation studies: DWR-1 980 Level (1922-1978); LISBR-2 020 Level (1895-1971). 

m Not Available. 



79 



In hydrology of the 11 years, 1922 to 
1925, 1930 to 1936, and 1976 to 1978, at 
the 1980 level of development, there 
were 15 months in which flow differences 
between the two cases could have an 
effect on salmon. Of these 15 months, 
the Proposed Action was more beneficial 
for salmon in 11 months and less bene- 
ficial in 4 months. The net effect of 
the differences cannot be expressed in 
numbers of fish, but the Proposed Action 
would be slightly beneficial overall, as 
compared to No Action, Case A. 

At the 2020 level of development, river- 
flows with the Proposed Action were more 
beneficial to salmon in 10 months and 
less beneficial in 3 months. The net 
effect would be slightly beneficial, and 
on about the same order of impact as 
would be observed at the 1980 level of 
development . 

The outlet structure at Oroville Dam can 

reach deep into the pool to take water 

of acceptable temperature in all or 
nearly all reservoir storage conditions. 

For this reason, the temperature impacts 

of the Proposed Action on salmon would 
be negligible. 

Increased drawdown during critical years 
could adversely affect resident fish and 
recreation use at Oroville Reservoir. 
Eagles wintering there would not be 
affected . 

The slight changes in flow of the 
Feather River in the Proposed Action, as 
compared to No Action, Case A, would not 
affect adjacent habitat used by the 
giant garter snake, Swainson's hawk, 
peregrine falcon, or California yellow- 
billed cuckoo. 



and October of critical year 1933 (1980 
level of development). Temperatures in 
these instances would be severely limit- 
ing for salmon spawning and rearing 
either with or without the Proposed 
Action. The impact of the incremental 
temperature change attributable to the 
Proposed Action (as compared to No 
Action, all cases) is probably on the 
order of several thousand fish lost . 

The Proposed Action would occasionally 
cause increased flows (as compared to No 
Action, all cases) below Folsom Dam and 
would less frequently cause decreased 
flows. The net effect would benefit 
salmon slightly, but this beneficial 
effect would be of a lesser order than 
the Proposed Action's adverse effect 
caused by temperature increases. 

Meeting the Exhibit A standards of the 
Proposed Action would require that 
Folsom Lake be drawn down farther in 
critical years than it might be if only 
the Tracy standards of No Action were 
being met. The increased drawdown could 
adversely affect resident fish and rec- 
reation use, although, as shown in 
Table 14, it is not significant. Also, 
the pumping requirements for water 
delivered directly from Folsom Lake 
would be increased , and some of the 
water users relying on this source could 
experience more severe water shortages. 

The Proposed Action would not signif- 
icantly increase flows of the American 
River and therefore would not affect 
adjacent habitat used by the valley 
elderberry longhorn beetle, Swainson's 
hawk, peregrine falcon, or sticky orcutt 
grass. Bald eagles would not be 
affected either. 



American River and Folsom Lake . Operat- 
ing CVP facilities on the American River 
to meet the standards of the Proposed 
Action's Exhibit A rather than the 
Bureau's Tracy standards could result in 
adverse temperature changes similar to, 
but smaller than, those described for 
the Sacramento and Trinity rivers. The 
difference would be 1 °F in May, June, 



No Action 

In the No Action alternative, facilities 
of the CVP, the SWP, or both would be 
operated to meet the Bureau's Tracy 
standards in critical years and the 
standards of Exhibit A in all other 
years. The three No Action cases are 



80 



the same in regard to operation of CVP 
facilities — they always operate to 
Tracy standards in critical years — so 
all three cases are the same in regard 
to effects on the Sacramento, Trinity, 
and American rivers. The three cases 
are different, however, in regard to 
operation of SWP facilities, and corres- 
ponding differences would be observed in 
the Feather River. 

Sacramento River and Shasta Lake . A 
proposed program of improvements, 
independent of the Proposed Action and 
No Action, should eventually restore 
Chinook salmon and steelhead populations 
to levels exceeding those of the 1970s. 
The improvements would consist of habi- 
tat rehabilitation (gravel restoration), 
pollution control measures planned for 
Spring Creek near Keswick Dara, more 
efficient and expanded hatchery opera- 
tions at Coleman Fish Hatchery and the 
Tehama-Colusa spawning channels, and 
possibly improvements in flow and water 
quality from Shasta Dam. Many of these 
potential improvements are being 
examined in the Bureau of Reclamation's 
Central Valley Fish and Wildlife 
Management Study, an 8-year, $2,650,000 
appraisal-level study seeking opportun- 
ities to improve fish and wildlife 
resources throughout the Central Valley. 
Structural and operational modifications 
to improve fish passage at the Red Bluff 
and Anderson-Cottonwood Irrigation 
District diversion dams and tributary 
dams have also been proposed. Some pro- 
posals are now being tried to evaluate 
their effectiveness. 

In the absence of measures to control 
temperatures of releases from Shasta 
Dara, Chinook salmon resources in the 
Sacramento River will decline signifi- 
cantly, primarily for mainstream spawn- 
ing populations of winter, spring, and 
early fall run chinook salmon. These 
declines will result from increased 
summer and fall water temperatures 
because of reduced Shasta Lake levels. 
In this regard, consequences of No 
Action and the Proposed Action would be 
the same, except the salmon declines 
attributable to high summer and fall 



water temperatures could be aggravated 
with the Proposed Action, at least in 
critical years. 

The potential for erosion problems on 
the Sacramento River would be greater 
with No Action than with the Proposed 
Action, because high flow periods would 
occur more frequently if higher carry- 
over storage were maintained at Lake 
Shasta . 

No Action would have no adverse impacts 
at Shasta Lake, as compared to the 
Proposed Action. 

Trinity River and Clair Engle Lake . 
Operating CVP facilities on the Trinity 
River as part of an overall CVP opera- 
tional scheme that involves meeting only 
the Tracy standards in critical years 
would not have adverse impacts on the 
Trinity River and Clair Engle Lake, as 
compared to the Proposed Action. 

Feather River and Lake Oroville . 
Impacts of No Action, Case A, in which 
SWP facilities are operated to meet only 
the Tracy standards in critical years, 
would be the reverse of the slightly 
beneficial impacts described for 
Proposed Action; i.e., conditions for 
salmon, as compared to conditions with 
the Proposed Action, would be less 
favorable. Impacts of No Action, 
Case C, in vhich SWP facilities are 
operated to fully meet Exhibit A or 
Decision 1485 standards even though the 
CVP is operating only to meet Tracy 
standards, would be the same as the 
impacts of the Proposed Action. Impacts 
of No Action, Case B, in which the SWP 
is operated to provide its share of the 
water needed to meet the Exhibit A 
standards, would also be the same as the 
impacts of the Proposed Action. 

American River and Folsom Lake . No 
Action would have no adverse impacts, as 
compared to the Proposed Action. The 
slightly beneficial flow impacts 
observed in the American River with the 
Proposed Action would be foregone, but 
so would the more significant (although 
slight) adverse temperature impacts. 



81 



Existing Central Valley Project 
Power Capabilities 

The Central Valley Project provides a 
significant portion of the hydroelectric 
power available for use in Northern 
California. Its nine power plants and 
two puraping-generating plants have an 
installed capacity of 1,750 megawatts 
(MW). Pacific Gas and Electric Company, 
the major power supplier in Northern 
California, has a net generating capa- 
city of 18,700 MW. Because 40 percent 
of this capacity depends on oil or 
gas-fired facilities, hydroelectric 
facilities, which do not depend on 
imported and non-renewable fuels and 
do not contribute to air pollution, are 
especially important. 

Most of the CVP power plants are just 
downstream from the storage reservoirs 
and are operated in conjunction with the 
water demands on these reservoirs. 
Thus, power generation is directly 
related to the irrigation, municipal and 
industrial, and other types of demands 
for project water. Recognizing that 
these water demands would be seasonal 
(with much larger releases being made 
during summer), CVP power plants were 
designed to generate peaking power. 
Since peaking power alone cannot satisfy 
the power requirements of CVP power 
customers, and since pnaaking is more 
efficiently used when integrated with 
baseload power, the Bureau of 
Reclamation entered into a support 
contract (Contract 2948A) with PGandE. 
The Western Area Power Administration 
(Western) now administers this contract. 
Contract 2948A provides for the delivery 
of peaking power from CVP power plants 
into the PGandE system; PGandE, in 
return, delivers power, as required, to 
Western's preference power customers. 

Power generated from the CVP system is 
dedicated first to meeting the power 
requirements of the project's pumping 
facilities. The remaining capability of 
the project's power facilities is used 
to provide commercial power to the 
various preference customers (irrigation 



districts, municipalities, military 
installations, and various Federal and 
State government installations) in 
Northern California. 

The commercial power accomplishments of 
the CVP are defined by two quantities: 
project dependable capacity (PDC) and 
energy. PDC is that portion of the 
CVP's installed capacity that can be 
relied on to meet preference customer 
loads under adverse hydrologic 
conditions. Energy (for commercial 
power purposes) is the electric energy 
generated as water is released from CVP 
reservoirs through the various power 
plants, less the demands of the CVP's 
energy-using facilities. In normal 
years, the CVP's plant hydroelectric 
generation for commercial power purposes 
exceeds 3,500 gigawatt-hours . The level 
of project dependable capacity the CVP 
provides is currently under dispute 
between Western and PGandE. 

The CVP is contractually committed to 
meet the preference customer load of 
1,152 MW through the year 2004. 
Western's Power Marketing Plan (October 
1981) indicates that the CVP will become 
energy short by 1991 unless it acquires 
additional power supplies. Western is 
actively searching for and has begun 
contracting for additional power. 



Effect on Central Valley Project 
Power Capabilities 

CVP power production capabilities with 
the Proposed Action and with No Action 
were compared using a computerized power 
operation model of the CVP. PDC was 
evaluated over the historical dry 
period, 1930 through 1934, in accordance 
with criteria established by the orig- 
inal Contract 2948A reclamation study. 

Both 1980 and 2020 levels of hydrology 
were used in the model. Hydrologies for 
these levels of development were 
obtained by modifying historical hydro- 
logic data to reflect year 1980 or year 
2020 demands . 



82 



Proposed Action 

The Proposed Action, which would entail 
both the CV? and SWF meeting Exhibit A 
standards in every year, would not 
significantly affect CVP average annual 
energy generation. No significant 
difference in average annual energy 
generation between the Proposed Action 
and No Action was observable in power 
operation studies at either the 1980 or 
2020 level of development. 



No Action 

Under all the No Action cases, the CVP 
would abide by the Exhibit A standards 
in all years except critically dry 
years, when the CVP would meet only the 
Tracy standards. This mode of operation 
would have no adverse effect on CVP 
power production capability, as compared 
to the Proposed Action. 



Related Actions and Projects 

The proposed Agreement would occupy a 
relatively central position, though not 
a commanding one, in the extensive and 
complicated system of water development 
that serves the people of California. 
The Agreement can be related in some way 
to all of the exsiting water projects — 
Federal, State, and local — in the 
40 percent of California that drains to 
the Sacramento-San Joaquin Delta, and 
because of imports to and exports from 
the basin, it can be related to projects 
in Southern California and the north 
coastal area as well. This section will 
discuss certain of these related proj- 
ects. In no case are the impacts of 
these projects impacts of the Proposed 
Action (executing the proposed Agree- 
ment) . 



Facilities Named 
in the Agreement 



The Article 3 facilities (diagrammed in 
Figure 16) are involved in the concept 
of storage withdrawals, which is import- 
ant to the sharing formula of Article 6. 
The Article 5 facilities are related to 
Exhibits B-1 and B-2 of the Agreement, 
and Exhibit B-1 in turn is related to 
the sharing formula. The sharing 
formula in Article 6 is based on compu- 
tations that operated the facilities in 
Article 5 to meet the water supplies 
specified in Exhibit B-l. 

Article 5 Facilities . The facilities 
listed in Article 5 can affect or be 
affected by the Coordinated Operation 
Agreement in three ways : 

By involvement in a storage withdrawal 
as defined in Article 3. In this 
category are the following Federal 
facilities: Shasta Lake, Keswick 
Reservoir, Clair Engle Lake, Lewiston 
Lake, Whiskeytown Lake, Folsom Lake, 
Lake Natoma. The following State 
facilities are in this category: Lake 
Oroville, Thermalito Forebay, 
Thermalito Afterbay, Thermalito 
Diversion Dam Reservoir, Lake Davis, 
Antelope Lake. 

By affecting export or export 
capability. In this category are the 
following Federal facilities: Contra 
Costa Pumping Plant No, 1, Tracy 
Pumping Plant, San Luis Reservoir, 
O'Neill Forebay. The following State 
facilities are in this category: 
Harvey 0. Banks Delta Pumping Plant 
(including Clifton Court Forebay), San 
Luis Reservoir, O'Neill Forebay, Lake 
Del Valle, Pyramid Lake, Castaic Lake, 
Silverwood Lake, Lake Perris. 

By affecting unstored flow available 
for export in the Delta. The Federal 
reservoirs Millerton and New Melones 
can affect unstored flow but cannot 
make storage withdrawals as defined in 
Article 3. They are discussed 
separately. 



The facilities or projects whose opera- 
tions are related to the Agreement are 
those named in its Articles 3 and 5. 



Friant Dam and Millerton Lake . Friant 
Dam is a Central Valley Project facility 
on the San Joaquin River, about 25 miles 



83 



northeast of Fresno. It impounds 
Millerton Lake, which has a capacity of 
520,000 acre-feet. The 150-mile Friant- 
Kern Canal diverts water southerly from 
Friant Dam to the upper (southern) San 
Joaquin Valley. The Madera Canal, about 
36 miles long, diverts water northerly 
from the dam. 

Prior to construction of Friant Dam, the 
water now captured in Millerton Lake was 
used downstream by diverters along the 
San Joaquin River. These San Joaqjin 
River flows have been replaced by 
Sacramento River water imported from the 
Delta and delivered to the San Joaquin 
Valley through the Delta-Mendota Canal. 

Although operation of Millerton Lake 
influences Delta inflows, and releases 
from Friant Dam could on rare occasions 
add to the unstored flow available for 
export from the Sacramento-San Joaquin 
Delta, the operation of these facilities 
would not be governed by the Agreement. 
They are operated independently of other 
CVP facilities and are considered, along 
with existing local projects, as part of 
the background conditions upon which the 
affected parts of the Central Valley 
Project and State Water Project are 
superimposed . 

New Melones Dam and Reservoir . New 
Melones Dam is on the Stanislaus River , 
about 60 river miles upstream from the 
confluence with the San Joaquin River. 
Operated by the Bureau of Reclamation as 
part of the Central Valley Project, the 
dam impounds up to 2,400,000 acre-feet 
of water. 

About 450,000 acre-feet of storage space 
in New Melones Reservoir is used for 
flood control. By year 2020, 131,000 
acre-feet of water per year from New 
Melones may supplement existing water 
supplies within the Stanislaus River 
basin and 49,000 acre- feet will be allo- 
cated to the Central San Joaquin Water 
Conservation District. Up to 70,000 
acre-feet is used to maintain water 
quality in the Stanislaus and San 
Joaquin rivers, and 98,000 to 148,000 
acre-feet is allocated for fish. 



Uncontrolled releases down the spillway 
of New Melones Dam could add to the 
unstored flow available for export from 
the Delta, but such releases would occur 
infrequently. If releases from New 
Melones were increased for water quality 
or fish, unstored flow in the Delta 
would increase. This would necessitate 
new operation studies for the 
Coordinated Operation Agreement, and 
renegotiation might be required. 



Other Projects and Actions 

This category includes proposed, poten- 
tial, and existing projects or actions 
not named in Article 5. Any future 
action that could have significant 
environmental impacts would be subject 
to supplemental or independent environ- 
mental impact reporting requirements and 
public environmental review. Construc- 
tion by either of the parties to the 
Agreement of any new facility that would 
change the water supply yield of either 
the Central Valley Project or the State 
Water Project would set in motion the 
negotiation process provided in 
Articles 14 and 16. A simulation study 
would be performed to determine the 
effect of the action or facility on the 
yields of the two projects. Any 
increase in yield would be credited to 
the party that built the facility or to 
both parties if the new facility was a 
joint venture. 

Some projects or actions discussed in 
this section involve "wheeling": con- 
veyance of one project's water through 
facilities of the other project. Such 
wheeling is not covered by the Coordi- 
nated Operation Agreement, except under 
Article 10(a): "Either party may make 
use of its facilities available to the 
other party for pumping and conveyance 
of water by written agreement." 

The projects or actions discussed below 
are not in order of importance. 

Suisun Marsh Plan of Protection . In 
Decision 1485 (1978), the State Water 
Resources Control Board ordered the 



84 




CO 



< 
cr 

Q 

I 



LU 

o 
< 

o 

I- 
co 



o 

UJ 

> 

-J 

o 

> 



CO 
LiJ 

o 

< 



CO 
Q 

z 
< 

Q. 
> 

■ • 

CD 



u. 
D 
D) 



85 



concerned "permittees", meaning the 
Department of Water Resources and the 
Bureau of Reclamation, to develop and 
implement a plan for protection for 
Suisun Marsh by July 1, 1979. The 
Department published the required plan 
early in 1984. Full implementation will 
be staged over a period of years. 

The plan calls for construction of 
facilities to improve the flow and 
distribution of Sacramento River water 
entering the marsh through Montezuma 
Slough. These facilities would be in 
addition to the "initial facilities" 
already constructed. First, a control 
structure would be placed across Monte- 
zuma Slough. When necessary to maintain 
desired water quality conditions in the 
marsh, the control structure would be 
operated with the tides so as to encour- 
age east to west flows that draw from 
the Sacramento River, and to block west 
to east flows that draw from Grizzly Bay 
(part of Suisun Bay). 

After Montezuma Slough Control Structure 
is in place, its effectiveness would be 
tested for several years to determine 
the need for additional facilities in 
the form of ditches for conveying water 
from Montezuma Slough into backwater 
areas of the marsh. The Department's 
Plan of Protection describes the 
proposed ditches. 

Part of the Plan of Protection is a 
contract being negotiated among the 
Department, the Suisun Resource Conser- 
vation District, the Department of Fish 
and Game, and the Bureau of Reclamation. 
The contract provides that the Suisun 
Marsh water quality requirements of 
Decision 1485 that were due to become 
effective October 1, 1984, will be met 
except in certain conditions of severe 
water shortage. In such conditions, the 
marsh would have to accept a deficiency 
in its water supply, as would other 
project water users. 

Four Additional State Pumps . The 
Department of Water Resources intends to 
install the last four of eleven pumps 



originally planned for Harvey 0. Banks 
Delta Pumping Plant, increasing the 
plant's maximum pumping capacity from 
6,400 to 10,300 cubic feet per second. 
The additional pumps are needed to: 

Provide standby pumping capacity to 
compensate for scheduled and 
unscheduled outages of the exsiting 
units. 

Reduce on-peak power and energy 
requirements for SWP pumping. 

Increase the firm yield of the SWP. 

The amount of energy saved and yield 
realized would depend on overall project 
operation. 

Environmental and socioeconomic impacts 
of the proposed pumps are described in a 
1982 draft environmental impact report. 

Delta Water Transfer Facility . Both the 
Department and the Bureau have proposed 
construction of Delta water transfer 
facilities to more efficiently move 
project water from the Sacramento River 
to the export pumps in the southern 
Delta. The Peripheral Canal, described 
in the Department's Bulletin 76 (1978) 
and in the Bureau's "Peripheral Canal 
Unit" feasibility report (1966), would 
be such a facility. The Peripheral 
Canal, however, was one of the water 
resources development projects included 
in State Senate Bill 200 (1980). Senate 
Bill 200 was submitted to a statewide 
referendum vote in June 1982 and 
rejected by the voters. 

Recently, the Department has suggested 
alternative water transfer facilities 
that would use existing Delta channels 
or existing channels plus one or more 
new channels. These plans differ from 
the Peripheral Canal in that the latter 
would have been one long and entirely 
new channel skirting the eastern 
periphery of the Delta. Construction of 
a Delta water transfer facility is one 
of the Department's highest priorities. 



86 



Among the purposes of a Delta water 
transfer facility would be to improve 
conditions for Delta fish and export 
water and to efficiently use stored 
water supplies by reducing or eliminat- 
ing reverse flow conditions. 

A Delta water transfer facility would 
improve the reliability of the supplies 
of the SWP, the CVP, or both, depending 
on whether the new facility were a joint 
facility and on how it would be 
operated. Decisions on joint operating 
procedures for minimizing shortages 
during droughts might also be affected 
(see Article 9 of the Agreement). 

North Bay Aqueduct . The Department of 
Water Resources proposes to build the 
North Bay Aqueduct as a State Water 
Project facility to deliver up to 60,000 
acre-feet of water annually from the 
Delta to service areas in central Solano 
and Napa counties. A final environmen- 
tal statement and environmental impact 
report on this project was completed in 
May 1982 /16/. Construction is 
scheduled to begin in 1984. 

The North Bay Aqueduct would divert 
water from Cache Slough, a channel 
contiguous with the Sacramento River, 
and convey it westward in a pipeline to 
supply the cities of Fairfield, 
Vacaville, and Suisun City. Near the 
town of Cordelia, this pipeline would 
join an existing pipeline segment built 
in the late 1960s as North Bay Aqueduct 
Phase I. The Phase I segment serves 
Napa County and has been operating with 
water purchased from the Federal Solano 
Project . 

Under the proposed Coordinated Operation 
Agreement, the North Bay Aqueduct would 
be considered an export facility for 
purposes of Article 5, because it would 
convey water out of the drainage of the 
Sacramento River and thus meet the 
definition of an export facility given 
in Article 16. 

Water for the North Bay Aqueduct would 
come from State storage withdrawals and 



from the State's share of unstored flow 
available in the Delta, 

Southern Delta Facilities . Portions of 
the southern Delta area suffer from one 
or more of the following problems: poor 
water quality, inadequate water 
quantity, poor water circulation, and 
low water levels at certain times and 
locations. These problems can be 
attributed, in varying degrees, to one 
or more of five basic causes: 

Central Valley Project operations. 
State Water Project operations. 
Nonproject water users. 
San Joaquin River degraded inflow. 
Existing channel conditions. 

At times, quantities and qualities of 
inflow to the Delta from the San Joaquin 
River do not meet minimum needs of agri- 
cultural diversions in the southeastern 
Delta. This problem is accentuated by 
water use upstream in the San Joaquin 
Valley and poor quality irrigation 
return flows, although since its 
completion, releases from New Melones 
Reservoir have lessened the problem. 

Some of the plans that have been pro- 
posed by the Department for Delta water 
transfer facilities would greatly reduce 
the problem of water level drawdown in 
the southern Delta, or at least that 
part of the problem that may be attrib- 
utable to SWP operations. To alleviate 
the remaining southern Delta problems, 
several alternative physical solutions 
have been proposed in the past. These 
include: 

Control structures, v^ich would induce 
higher water levels and circulation. 

New distribution channels. 

Dredging existing channels. 

Extension of Tom Paine Slough to the 
San Joaquin River so that water could 
be pumped from Old River into the San 
Joaquin River to provide circulation. 



87 



No plan is now active for implementing 
any of these potential solutions. All, 
however, would be compatible with a 
Delta water transfer facility plan and 
could be integrated with such a plan. 

The South Delta Water Agency has filed a 
suit against the U. S. Bureau of 
Reclamation and the Department of Water 
Resources alleging damage to the south- 
ern Delta because of the effects of the 
Central Valley Project and the State 
Water Project on water quality and water 
levels. Responsibility for alleviating 
these problems has not been determined. 

North Delta Water Agency Contract . In 
January 1981, the Department of Water 
Resources signed a contract with North 
Delta Water Agency for a dependable 
water supply. The Agency represents 
agricultural water users in northern and 
western portions of the Delta. 

The contract sets water quality 
standards to be met by the State Water 
Project and requires the Agency to pay 
for benefits arising from project opera- 
tions. (The Bureau of Reclamation is 
not a party to this contract.) The 
standards are parallel to Decision 1485 
standards, but at times are more strin- 
gent. The extra outflow required to 
meet these more stringent standards 
could reduce the critical period yield 
of the State Water Project by more than 
100,000 acre- feet per year. The 
contract also provides that "the State 
may provide diversion and overland 
facilities to supply and distribute 
water to Sherman Island", and that 
"after the facilities are constructed 
and operating, the water quality 
criteria ... shall apply at the intake 
of the facilities." 

The Department is bound to the contract 
regardless of future changes in Decision 
1485 standards. However, due to differ- 
ences between water quality standards in 
Decision 1485 and the North Delta Water 
Agency contract, it is appropriate to 
consider Sherman Island separately from 
other western Delta islands. 



Preliminary plans for an overland system 
for Sherman Island show that it must 
deliver up to 6,500 acre-feet per month. 
The system would consist of: 

° Diversion from Threemiie Slough 
through automatically controlled 
siphons. If diversion at Threemiie 
slough does not provide good enough 
water quality water, the point of 
diversion would be moved upstream to a 
point where contract quality could be 
maintained. 

Transport to the Main Canal through a 
new canal parallel to Highway 160. 

Conveyance and storage in the Main 
Canal and Mayberry Slough. 

Distribution through seven gravity 
laterals and five pump laterals. 

Final design and specifications would be 
subject to approval of the North Delta 
Water Agency and of Reclamation 
District 341. The Agency or its 
transferee would assume ownership and 
full operation and maintenance 
responsibilities for such facilities 
after successful operation was 
demonstrated . 

Estimated cost of the facilities is 
$11 million. Building such facilities 
would prevent the possible loss of more 
than 100,000 acre-feet of yield to the 
State Water Project. This assumes that 
the contract criteria would be measured 
at the intake of the facilities and that 
there would be no change in Decision 
1485 standards. The Department intends 
to build these facilities in the near 
future . 

The requirements of the North Delta 
Water Agency contract are binding only 
on the Department of Water Resources, so 
any additional water needed to fulfill 
the contract above the requirements of 
Exhibit A of the proposed Coordinated 
Operation Agreement would be solely the 
Department's responsibility. 



88 



Contra Costa Canal Intake Relocation . 
Over the past two decades , many pro- 
posals have been made for relocation of 
the intake of the Contra Costa Canal. 
Water quality at the present intake 
location, on Rock Slough, is subject to 
degradation by ocean salts advancing up 
the lower San Joaquin River during low- 
flow periods, and by local agricultural 
drainage during high-flow periods. 

The value of relocating the intake 
depends on what, if any. Delta water 
transfer facilities may be constructed 
in the future. Most of the Delta 
transfer plans under consideration could 
eliminate reverse flows in the lower San 
Joaquin River, which would prevent 
intrusion of ocean salts in the Rock 
Slough area. With water quality at the 
present intake thus protected, 
relocating the intake would mainly serve 
to avoid adverse water quality effects 
attributable to the local drainage 
problem. Such local effects could be 
overcome by engineering means other than 
relocating the intake. 

Additional Offstream Storage South of 
the Delta . One way to increase the 
water supply yields of the CVP and SWP 
involves increasing the projects' 
capacity to store water exported from 
the Delta. At present the projects can 
store significant amounts of export 
water only in the joint Federal-State 
San Luis Reservoir, near Los Banos. 
Storage capacity could be increased by 
building additional surface storage 
facilities or by using natural ground 
water basins for storage. Either way, 
the additional storage space is usable 
only if excess water is available in the 
Delta and the projects have conveyance 
capacity to transport this water to the 
place of storage. 

The Department of Water Resources has 
investigated many possible sites for 
surface and subsurface offstream storage 
south of the Delta. (Offstream means 
not in the direct course from the 
collection of water, as in a watershed, 
to its delivery and use.) The surface 



sites are all in the hills just above 
the western fringes of the San Joaquin 
Valley and near the California Aqueduct. 
The subsurface sites are in the southern 
San Joaquin Valley, Southern California 
and the southern San Francisco Bay area. 
The effectiveness of all the potential 
sites for offstream storage is limited 
by pumping capacity at the Delta, and in 
some cases by aqueduct capacity as well. 
Installation of additional pumps 
proposed for the SWP's Banks Pumping 
Plant would make all of the offstream 
storage proposals more feasible. 

Recently, the Department has expressed 
interest in constructing the Los Banos 
Grandes offstream reservoir, v^iich would 
be located about 3 miles south of the 
existing San Luis Reservoir. The new 
reservoir would be designed to store 
excess water that would otherwise flow 
to sea in winter. It would provide more 
flexibility in timing Delta diversions 
to meet the various seasonal needs of 
salmon, steelhead , and striped bass. 
The full effectiveness of Los Banos 
Grandes could not be realized without a 
Delta transfer facility and the proposed 
additional SWP export pumps, 

Cottonwood Creek Project . The U. S. 
Army Corps of Engineers has proposed to 
construct two dams and reservoirs on 
separate forks of Cottonwood Creek, the 
largest remaining uncontrolled tributary 
of the Sacramento River. Under a 
contract with the Corps, the State Water 
Project would obtain water storage 
capability in these reservoirs worth an 
estimated 150,000 acre- feet in annual 
project yield. 

The Cottonwood Creek project would give 
the State Water Project greater flexi- 
bility in storing water and making 
storage withdrawals. Potential environ- 
mental effects of the Cottonwood Creek 
project are reported in a Corps of 
Engineers document, "Cottonwood Creek, 
California; Draft General Design 
Memorandum; Phase I, Plan Formulation; 
Main Report, Part II, Environmental 
Impact Statement", dated June 1982. 



89 



State Purchase of Central Valley Project 
Yield. The Department of Water 
Resources has expressed interest in 
negotiating a contract for purchase of 
Central Valley Project water to assist 
each project in making more efficient 
use of water supplies. This water can 
be recalled if needed by existing or new 
long-terra CVP contractors. 

Executing a purchase agreement would be 
a discretionary governmental action 
having potential for significant 
environmental impacts. Requirements of 
the National Environmental Policy Act 
and California Environmental Quality Act 
would, therefore, have to be satisfied 
before any such agreement were executed. 
Executing the draft Coordinated Opera- 
tion Agreement is not a prerequisite. 

Trinity River Fish Flows . In a 1980 
study, the U. S. Fish and Wildlife 
Service evaluated eight alternative 
plans for flow releases from the CVP ' s 
Lewiston Dam into the Trinity River to 
improve fish habitat and production. 
The alternative releases considered 
ranged from 120,500 acre-feet per year 
(the minimum release level then in 
effect) to 340,000 acre-feet per year. 
At the conclusion of the study, the Fish 
and Wildlife Service recommended releas- 
ing 340,000 acre- feet in normal years, 
220,000 in dry years, and 140,000 in 
critically dry years. Such releases 
would reduce CVP water supply yield by 
about 4 percent as compared to CVP yield 
with the original minimum release 
levels . 

In 1981, the Secretary of the Interior 
approved the Fish and Wildlife Service's 
recommended releases for a 12-year 
experimental period. However, until a 
stream habitat management program is 
completed, maximum annual releases will 
be 286,700 acre-feet in normal years. 

The 1980-level operation study used for 
Exhibit B-1 of the draft Coordinated 
Operation Agreement assumed the Trinity 
releases recommended by the Fish and 
Wildlife Service. The 2020-level 



studies used the original 120,500 
acre-foot minimum releases from Trinity. 

Exhibit B-2 would have to be recalcu- 
lated with a reduced CVP yield if the 
Fish and Wildlife Service's flow recom- 
mendations were adopted permanently. 

Auburn Dam and Folsom South Canal . 
These CVP components, both partly com- 
plete, involve further water development 
in the drainage of the American River. 
The Auburn Dam site is on the North Fork 
American River, near Auburn. It was 
planned as a 700-foot-high , thin-arch 
dam, impounding a 2.4 million acre-foot 
reservoir. Seismic safety concerns 
halted construction after extensive site 
preparation, but no actual dam building 
had started. The project will remain 
uncompleted until alternative plans are 
evaluated and Congress reauthorizes the 
project. The Bureau of Reclamation is 
seeking participation of non-Federal 
entities in financing the dam. 

Folsom South Canal, with an initial 
diversion capacity of 3,500 cubic feet 
per second, originates at Lake Natoraa, 
an afterbay of Folsom Dam, V(*iich is 
downstream from the Auburn Dam site. 
The first two reaches, about 27 miles, 
have been completed. The complete canal 
would be 69 miles long and serve indust- 
rial, municipal, and irrigation users in 
Sacramento and San Joaquin counties. 
About 17,000 acre- feet is now being 
delivered annually to the Rancho Seco 
Powerplant of the Sacramento Municipal 
Utility District. 

If Auburn Dam and Folsom South Canal are 
completed, up to 590,000 acre-feet could 
be delivered annually in the Folsom 
South service area. If neither is 
completed, up to 350,000 acre-feet could 
be delivered annually through the two 
existing reaches of the canal. Water 
users might have to build their own 
facilities to transport water from the 
end of Reach 2 to the place of use. 

Several of the alternatives being 
considered for completion of Auburn Dara 



90 



would involve meeting most or all of the 
requirements in State Water Resources 
Control Board Decision 1400. That 
decision specifies minimum flows in the 
American River for recreation and fish. 
These flows could be provided while 
still meeting needs of the Folsora South 
service area by operating a new pumping 
station on the Sacramento River that 
would pump water eastward via several 
new canals to a new reservoir, which 
would release water to Folsora South 
Canal . 

The studies that produced Exhibits B-1 
and B-2 of the Agreement did not assume 
completion of Auburn Dam or Folsom South 
Canal. Flows roughly equivalent to 
Decision 1400 requirements were main- 
tained in the American River in the 
1980-level study for Exhibit B-1. Much 
lower minimum flows, down to 250 cubic 
feet p)er second, were assumed for the 
2020-level study that produced 
Exhibit B-2. 



These facilities are required to meet 
projected water demands, prevent further 
mining of the ground water in Santa 
Clara County, and replace boron- 
contaminated water and stop land subsid- 
ence in San Benito County. Santa Clara 
County would ultimately receive about 
152,500 acre-feet annually, and San 
Benito County would receive about 43,800 
acre-feet annually. 

Water would be developed by existing 
facilities of the CVP and would be 
conveyed through State or Federal facil- 
ities to San Luis Reservoir. From the 
reservoir, the Pacheco Tunnel will 
convey water to a series of canals, 
pumping plants, and conduits to both 
counties. Existing reservoirs in the 
Santa Clara area and the planned San 
Justo Reservoir will store and control 
the water. The project is scheduled for 
completion in 1988. The San Felipe 
division was included in the studies for 
Exhibit B-2. 



San Luis Unit . A Federal-State inter- 
agency team is identifying and evaluat- 
ing alternative proposals to solve the 
problem of agricultural drainage in the 
San Joaquin Valley, including the San 
Luis Unit and Delta-Mendota Canal 
service areas. The recommended alterna- 
tive may include amending the water 
service contract with Westlands Water 
District to increase the long-terra 
commitment of water by 250,000 acre- feet 
from the San Luis Unit. 

The completed San Luis Unit was included 
in the Coordinated Operation Agreement 
operation studies. At present, addi- 
tional water is being delivered to the 
unit on a temporary basis. Amending 
contracts with the District would have 
no effect on the Agreement. 

San Felipe Division . The San Felipe 
Division of the CVP will eventually 
serve parts of Santa Clara, San Benito, 
Santa Cruz, and Monterey counties. 
Facilities are under construction to 
convey water to Santa Clara County and 
the Hollister area of San Benito County. 



Cross Valley Canal . Kern County Water 
Agency's Cross Valley Canal is part of a 
delivery system used to supply CVP water 
from the Delta to agricultural users 
near to and north of Bakers field. CVP 
water actually delivered to these 
customers is water from Millerton Lake, 
delivered through the Friant-Kern Canal, 
that would otherwise be delivered to the 
Arvin-Edison Water District, south of 
Bakersfield. By delivering Delta water 
to Arvin-Edison through the Cross Valley 
Canal, the Friant-Kern water is released 
for use north of Bakersfield. 

Water for delivery through the Cross 
Valley Canal is captured in Federal 
reservoirs north of the Delta and 
delivered down the Sacramento River 
system for diversion from the Delta, 
However, the CVP's Delta-Mendota Canal 
is too small to carry the extra water 
from the Delta to O'Neill Forebay, and 
the San Luis Canal (the Federal-State 
segment of the California Aqueduct) ends 
at Kettleman City. The Cross Valley 
Canal intercepts the California Aqueduct 
65.7 miles south of Kettleman City, at 



91 



Tupraan. Therefore, the CVP water must 
be wheeled 63.4 miles through the Calif- 
ornia Aqueduct from the Banks Pumping 
Plant to O'Neill Forebay and 65.7 miles 
from Kettleraan City to Tupraan. 

In 1977, a critically dry year, the 
Bureau of Reclamation wanted to make 
deliveries through the Cross Valley 
Canal from San Luis Reservoir during a 
period when the CVP was not operating in 
compliance with the then-current State 
Delta standards. The Department of 
Water Resources refused to wheel water 
for the Cross Valley Canal through State 
facilities. Since 1977, the CVP has 
been operated in compliance with State 
Delta standards, and v^eeling for the 
Cross Valley Canal has not been cur- 
tailed. With the Proposed Action, CVP 
compliance with the Exhibit A Delta 
standards would be guaranteed. 

A portion of the total CVP water supply 
in Exhibits B-1 and B-2 is allocated to 
the water users served by the Cross 
Valley Canal. 

Mid-Valley Canal . Mid-Valley Canal, a 
proposed CVP facility that has not been 
authorized, was planned to convey about 
500,000 acre-feet per year of Central 
Valley Project water to serve portions 
of Merced, Madera, Fresno, Kings, and 
Tulare counties and, by exchange, fur- 
nish water to Kern County. The project 
would alleviate part of the serious 
ground water overdraft in the area. 

Water would have been conveyed from the 
Delta to near Mendota Pool by the Delta- 
Mendota Canal, enlarged in capacity by 
2,000 cubic feet per second. At Mendota 
Pool, the water would be lifted into two 
new canals: a 110-mile Mid-Valley Canal 
for use in Fresno, Kings, and Tulare 
counties; and a 39-mile North Branch 
Canal for use in Madera and Merced 
counties . 

The Mid-Valley Canal would not affect 
Exhibit B-1 or B-2 because it would only 
transport uncontracted water. However, 



because it would be a new facility, 
construction of the Mid-Valley Canal 
would occasion a review of the 
Coordinated Operation Agreement. 

Enlarged Shasta . In 1983, the Bureau of 
Reclamation and the Department of Water 
Resources began a study of feasibility 
of enlarging Shasta Lake. The enlarge- 
ment has been proposed to increase water 
supplies for the Central Valley Project 
and State Water Project, increase power 
generation, improve fisheries and 
recreation, and provide additional flood 
control along the Sacramento River. The 
existing Shasta Lake can store a maximum 
of 4,552,000 acre-feet. Studies have 
considered various increases in the dam 
height, up to a maximum of 200 feet. A 
200-foot increase would create about 
9.5 million acre-feet of additional 
storage space at the lake. About 25 
structural and nonstructural alterna- 
tives to enlarging Shasta have also been 
evaluated. 

A joint status report on enlarged Shasta 
studies is scheduled for completion in 
1985. 

An enlarged Shasta would activate 
Article 14, "Periodic Review", and 
Article 16, "New Facilities", of the 
Coordinated Operation Agreement. The 
Agreement might have to be amended. New 
operation studies would be done to 
determine the increase in yield for both 
the SWP and the CVP. 

Tehama-Colusa Canal . As now planned, 
the Tehama-Colusa Canal will extend 111 
miles from the Red Bluff Diversion Dam 
to Yolo County. It will eventually 
supply 450,000 acre-feet of water annu- 
ally. About 59.3 miles of the canal 
are in operation. The remaining reaches 
of the canal are nearly complete. 

Exhibit B-2 covers the full deliveries 
of this canal. 

San Joaquin Conveyance Study . The 
Bureau of Reclamation began the 



92 



San Joaquin Conveyance Study in 1982. 
The purpose of this study is to develop 
plans for facilities to import 
additional water to the San Joaquin 
Valley to relieve existing ground 
water overdrafts. The study area 
includes the entire San Joaquin Valley, 
mainly San Joaquin, Stanislaus, Merced, 
Madera, Fresno, Tulare, Kings, and 
Kern counties. The study is a joint 
effort between the Bureau and the 
Mid-Valley Water Authority, which is 
made up of about 30 counties and water 
districts . 

About 2 million to 2.5 million acre-feet 
of water per year is needed to replace 
supplies presently obtained from ground 
water overdrafts. Potential water 
resources in the Sacramento Valley are 
the most likely new sources of water, 
including the unfinished Auburn 
Reservoir, enlarged Shasta Lake, and 
several offstream alternatives to 
enlarged Shasta. 

Several potential programs for 
delivering additional water to the 
San Joaquin Valley have been studied. 
The Mid-Valley Canal is one. An East 
Side Canal was analyzed in the 1960s 
as part of the Bureau of Reclamation's 
proposed East Side Division. The canal 
would have extended 334 miles from the 
American and Sacramento rivers to 
Bakers field, and would have operated 
in conjunction with five new offstream 
reservoirs. The East Side Division 
plan was deferred. Other potential 
programs for the San Joaquin Valley 
include conjunctive use of surface 
water with ground water supplies 
(including artificial ground water 
recharge), new storage facilities, 
waste water reclamation, and water 
conservation. 

No plan has yet been devised for the San 
Joaquin Valley Conveyance Study. 
However, the plan eventually selected 
will include water conservation and 
ground water management. 



Relationship Between Short-Term 
Uses Of The Environment and 
Long-Term Productivity 

No issues regarding the relationship 
between short-term uses of the environ- 
ment and the maintenance and enhancement 
of long-term productivity need arise in 
connection with the Proposed Action. 
The Proposed Action has to do with how 
existing long-term uses of the envi- 
ronment by the CVP and SWP will be 
coordinated. If the parties to the 
Proposed Action perceive at some time in 
the future that the Proposed Action is 
not in the interests of long-term 
productivity, the Proposed Action may be 
changed, invalidated, or abandoned. 
Residual effects in such a situation 
would be minimal and short-lived. 



Adverse Environmental Effects 
That Cannot Be Avoided 

The Proposed Action has to do with how 
the Central Valley Project and the State 
Water Project will be operated, but it 
would not constrain operations to such a 
degree that an adverse environmental 
impact resulting from the Proposed 
Action would be unavoidable. The same 
would be true for No Action. 

If operation under the proposed Coordi- 
nated Operation Agreement is found to 
cause adverse environmental effects, 
operations can be adjusted within the 
scope of the Agreement or the Agreement 
can be changed. Adverse water tempera- 
ture impacts of the Proposed Action, 
(see "Environmental Consequences, Rivers 
and Reservoirs") may be difficult to 
avoid in extremely dry years. 



Irreversible or Irretrievable 
Commitments of Resources 

Neither the Proposed Action nor its No 
Action alternative would involve irre- 
versible or irretrievable commitments of 



93 



resources. The Proposed Action would 
commit quantities of water for the 
Sacramento-San Joaquin Delta and Suisun 
Marsh, but this commitment would not be 
irreversible. The water committed would 
not be irretrievable except in the time 
frame of as many hydrologic years as may 
be required to fill the reservoirs once 
they are drawn down. 

The proposed Coordinated Operation 
Agreement includes, in Article 14, a 
procedure by which the Agreement may be 
changed and a procedure by which the 
parties could terminate the Agreement. 



Urban Quality, Historic and 

Cultural Resources, and the 

Design of the Built Environment 

The Proposed Action would have no 
effect on urban quality, historic, and 
cultural resources, or on the design of 
the built environment. 



on an overall basis, provide added envi- 
ronmental protection. If new project 
facilities are built, they will have 
their own environmental documents. The 
general expected effects of possible 
future water planning actions are 
presented in Table 15. 

In addition to SWF and CVP water plan- 
ning actions, many factors have affected 
and will continue to affect the estuary 
cumulatively. Among these are: 

" Land reclamation and bay fill. 

° Sediment load from early gold mining 
activity. 

° Toxic chemical, pesticide, and waste 
water pollution from cities, farms, 
and boaters. 

° Concentrated salt loadings from 
irrigation and soil leaching 
agricultural activities. 



Case C of the No Action alternative, in 
which the State Water Project would lose 
some of its yield so as to assure meet- 
ing the Delta standards of Decision 
1485, could adversely affect the built 
environment in urban areas that rely on 
the SWF. 



Possible Conflicts 
With Governmental Plans 

The Proposed Action would not conflict 
with any Federal, regional. State, or 
local land use plans. 

The No Action alternative would conflict 
with the State Water Resources Control 
Board's Water Quality Control Plan for 
the Sacramento-San Joaquin Delta and 
Suisun Marsh, which incorporates the 
Decision 1485 Delta standards. 



Commercial, sport, and illegal 
fishing. 

Construction and maintenance of ship 
channels. 

Use of natural inflows by upstream and 
Delta agricultural and urban 
development . 

Direct diversions and thermal 
pollution of power plant operations. 

Increased urbanization around the 
Bay-Delta area, resulting in loss of 
valuable wildlife habitat. 

Agricultural practices and crop 
patterns that decrease the value of 
the Delta to wildlife. 

Levee maintenance programs in which 
riprap replaces riparian habitat. 



Cumulative and 
Growth-Inducing Impacts 

As long as no new project facilities 
are built, the Proposed Action would. 



Upstream storage and regulation of 
natural inflows by the Hetch Hetchy 
Aqueduct, Mokelumne Aqueduct project. 
Central Valley Project, State Water 
Project, and others. 



94 



z 
a 





Ul 




s 




5 




w 




y 




s 




1-^ 




U) 




10 




o 




CL 


in, 


h 


e 


M 




H- 


5 





z 
o 



a 
w 

u 

UJ 
0. 
X 



•^ 


c fl 


•D 


T3 


a 


(D O --1 « 


O 


O 


> 


(3 JJ u 91 


CO N 


CD N 


u 


J-» -w 


JJ T-t 


a 

n 


Fbaaii 
reduc 
of ca 
water 
relea 


H 




.3 


c^t 


^•g 



i^^ 



u 
eg o 

& 



« 

<D 
£1 



I 

o 

so a 

o ^ 
I/) 

s 



-4 09 

e o 

■rt > 



s< 



8^ 

bi o 

s ^ a 

^<§-= 

a. • 
» o 
u (/> 



09 
^ O 

8ii 

id s 

> o 
uz 



was 
-4 j: o 
V u u 

O kl kl 



— . 10 

,nj c 



e 3 
.1^ 



C 



!-S 



Si 



C CO 

U Q\.U U Co 

03 C o 2J ^ 

*J -rH 3 g k. 

c ■- -o e o 

.^ a. B 3 c 

X CS b CO -ri 



■D ra 



cs S 

Oj u 
u Z 

O CT O 



5 ^ 



S5 



U CO 




CD 


u u 


L4 


O 


£ (-• 


(U 


U 


S o 


■H 


o 



cS.^ 



x ra 
cri cu 

1 _ o 
C o u 
•H -D 



ra s 

£1 

CJ CD 



u ra 

J^ c-i 
c o 



^ 0) 
3 ■- 
O CJ 



s o 



ra 
o 



O 3 


1^ c 


ra 85 


00 o u 


•O S 


la 1- 


C 0) o 


t- z 


OJ £ OJ 


O CT ° 


a. u u 



o — o 



u 



tl ra 5 . 

0} 0) e u 

jj U .,H T3 

■u u c 

0) c -H c 

3 H S H 



§.3 






m oj en C 
Q *j to ■-« 



3— . 


a 


^2 


i2C 


CD n 


ra 
ra 3 


*J CD 


JJ c 



_. o --. 



a =: 



CD <y o *^ oj 

-^ ™ u C ^^ X N 

.1^ n -H (-• o -H 

i eg 

o e 



OJ 



V c 



^ u ^ 3 g 

o ra ra «H 3 
a. o z . 



raS 



il 



3 Z 
™ O 



5-y 



^ CO 

2 CO 
— a ■ 



0) ra 



03 O 
^•-1 E 

kl XJ 3 
U Q S 
iJ 3 -H 

•H 8 ra 



ra 

5 
^-> -• 

ki a^-*-i 

OJ C CJ 
^•-13 

S CO u 



C CD 5 

O E O 

a. u b4 

CD OJ CT 

O ^ CD 



■y 


"ra 


o 


c 


a 


3 


•^ 


ra 




OJ 


S 


tn 



S9? 



sy 



""2 



U 4-) 

a c 

E 4-) 

03 Q. 



CD B 



ii y 



CD 
U O 

■r-t O 



I 



C 3 o-^ 



fl 



0) hH 

> J^ 4-) C (-• 

O CD C OJ 

t^ u O OJ CO 

Q. 0^.i_) lj CO ^ .^ 



CT*J O 

-I C -• 

e OJ 

T3 g P o 

> 3 JJ 

o — <a CJ 

k, = «) 3 

Q. o ki -n 

e -^ Q o 

*^ -4j ra ki 



0) k. 

<a ,3 



OJ 



ra ra z ra -w 

o — o « 

ki 3 Z ki OJ 

p-1 ki 14. T3 ^ 



O _ 



-a 


^S 






c 


■*H 


•»-< 


S* 




o 




1 






fH 


•rH 


•^ 




■4J 


13 




c 


ra 


CO 


.r^ 


-H 


OJ 


8 


(-• 


X 


E 


OJ 


(D 


(D 




kl 


3 


c9- 


u- 


O 
•*J 


s 



ra c 
0) S 




k. o 


o u 


m 


.sa 


o 



-o pi 

0) •^ 
CD C 0) 

0} 5 u 
(H o n 

O u 03 



z 

■S !° 

4j ra UJ 01 

C kr CJ U 

OJ CI) ra 3 

3 B g 8 
a. C7I-H u 



s^ 



CD ■»« 

u > 

CO u ^^ 

= ^ (-. 

CD -H O 

e X > 



jj CO o 

c aj-D 
u U z 

4.} O CO 

p C t- 

Q. -H "D 



a (U -^ CO 

^ u w 5 - 

4-» o ^ o t- 

C S -H -' OJ 

03 X ^ -^ 

£,o — ■ r CO 

'*- '^ -H Q. 



C (0 o c 

U -H O CD 

OJ <«- CO ^ 

(D CO — • 03 r - 

Q. O ^ 4_i CD O 

^ cn-w o -H 

X c as CD - 03 

O CO 33 Q, O O 



Bora 


T3 gi,3 o 


(4- 

•H 

c 


jj ra 3 


crea 
reen 

8303 

at 3 
crea 
hors 


CT 03 


m k. 8^ z 


•3 ? 


CO O i- 3 


ra 


ij-S§c 


& ^2.15,% 


5€ 



tjl 



c 

•<-• 0) 

(D — 

4.J 03 

OJ C > 

1- -H 0) 

?-H CD -^ 
3 E 

mH > u 

4-1 (J "O 03 

CD Q — ' -C 

tH 03 3 cn 

X aj o -H 



00 



I 



C 03 
■H ^ 
Ql-H CD CT 

c o e -W 
mh > j: 0) 

oa CJ ^ c 03 

-H 03 D ■<-< > 
X V 3 CD 03 



CD 

5€ 



c 

C31 0) 

n 

5-g 



8 c "Q -^ 

ra z c ^ CO 

ra 3 ra ra ^ 

OJ "D OJ o 

kl Z ^ b CO 

a ra 01 o Q. 

'-' T3 Ci- k, ^ 



c 

c "o — I 

ra z 2 ^ a 

ra 3 ra ra 4_j 

OJ 13 OJ o 

kl 2 JT t- m 

Q ra en o ci 

C b ..M C E 

■-1 ISC'- u ,H 



I CO 



a — !•- ^ 
ra u OJ CO 

OJ 0) -H 



3 i3 



t 
c CD ra 

•r-l 0) *J T3 ■ 

o o = • 

ra ^ OJ ra 

S — tl- ^ 

ra kl o ra 

OJ OJ .H 

- o u_ 



.:; 3^ 



3 ^ 3 ra 
m -H 3 z 



a o ' 



ra 



ra ra 



X 3 

0) c 

ra 

c<- £ 

3 CJ 



■o •• 




o,o 




jjiS 




O'H 




■D— • 




c-o 


00 


3 — — 


OJ 


Crf ra 

-4 Z U 


o 


kl 


\ 3 


3 


■s^^ 


3 


ra-H 3 


OJ 



— « (D U- C 

'^ 2 5- ° 

- CT-Q .-* 

■^ CT OJ e-t CD CD 
-- C -iJ OJ U 

3 CO 4-1 4j >s a^ 
g ^ n CD 4-» -H 

a o a s -H e 



C 03 03 .U 

•H 00 4J -^ .f^ 

O O - — 

00 Q. 0) CD ^ 



: — jJ (0 



Cm "■ CO 

3;^ 03 -H CJ 

C "*- CO o 

■H .— H U '- 

Tj— 3 3 

ra ra<w 3 CJ 
-i-u sou 



id 

-n CD 
03 "D t- 

-O p OJ 



"2 

ra ra 

^ 03 

en 

03 3 

— ra 
ra 



o 
3 ra 
a. 3 





03 


X 


CD 












c 


0) 


03 




u 


03 


O 












^ 


03 


4.J 








(-■ 








C 






O 


O 


CT» 


OJ 


^ 


■g 


i 


■a 


3 




03 
GJ 


Q. 


OJ 


C 




tir 


»H 




E 


■H 


09 


^ 


03 


03 




(^ 




00 






CD 


o 


ra 


ra 


4^ 


CD 


Ui 


CJ 


5 


% 


0} 


O TJ 




03 


CJ 


OJ 


QJ 




OJ 


00 


•J 


u 


z c 


kl 


CD 


b 


g 


OJ 


(-1 


03 




(-« 


Si 


ra 


03 


S 


a 


U 






g 


O 


u- 


O 


kl 


■H 


^ 


a 


3 j3 


tW 




•H 


a. 


■^ 


-a 


c^ 


u 


^ 


3) 


•»H 



&s 



03 

kl C 

-H 3 

O -rt 

> 1.J 

k4 (0 

03 kl 

CO (Q 

csa- 



^ 



§ 



s 



■gr: 


u. 




4J 

03 ra 


CO (D 




03 


— 1 kl 


00 


CD 


■•-) 


a a 


2 


^a 


1% 


H b 


i 

4J 


-1 u 


4-) 


Z c 


S.-8 


3i 


c2 


OJ o 
c o 


c 

10 -r< 

OJ ra 
*•» u 
(0 ^ 




01 




o cc 




4J 




rt c 




8 




?3 




<!. 




r-4 




(fc. 




U 




Ui 




>. OJ 




8 




55 



95 



Delta diversions by the Central Valley 
Project, State Water Project, local 
Delta municipal and industrial water 
users, and Delta agricultural water 
users . 

Levee failures in the Delta. 

Wavewash erosion caused by boat 
traffic . 



Wheeling Arrangements 

Article 10(h) of the proposed Agreement 
commits the parties to begin negotia- 
tions toward a separate contract that 
would specify arrangements whereby 
excess capacity in the pumping and con- 
veyance facilities of the SWP would be 
used to increase the amount of water the 
CVP can deliver from the Delta. This is 
a separate action, requiring a separate 
contract or agreement and a separate 
environmental impact report. With its 
present Delta export facilities, the CVP 
lacks the pumping and conveyance 
capacity to deliver to its existing and 
potential contractors south of the Delta 
all the potentially exportable CVP water 
available in the Delta at certain times. 
The SWP has capacity in the California 
Aqueduct for (Reeling CVP supplies. 
With wheeling through SWP facilities, 
the effect of the CVP ' s capacity limita- 
tion would be lessened. However, the 
SWP ' s capacity at Banks Pumping Plant is 
only about 60 percent of the California 
Aqueduct's capacity, and additional 
pumps would have to be installed to 
allow a significant increase in v^ieeling 
for the CVP. 

Wheeling of the type covered under 
Article 10(h) could represent increased 
export from the Delta. Such v^eeling is 
distinguishable from other wheeling 
covered londer Article 10 by the fact 
that the other wheeling, for outages and 
to make up for the May-June pumping 
restrictions of Exhibit A, is already 
established practice and serves only to 
maintain, and not expand, the water 
supply services of the SWP and CVP. 



To the extent some wheeling arrangement 
negotiated pursuant to Article 10(h) 
could increase project exports from the 
Delta, the increase could cause environ- 
mental impacts incremental to those 
associated with the existing level of 
project operations. However, any future 
wheeling arrangement would have to be 
carried out within the protective flow 
and quality provisions of the State 
Water Resources Control Board's Delta 
standards and would require a separate 
EIR/EIS and contract. 

Any incremental impacts of wheeling 
arrangements negotiated pursuant to 
Article 10(h) cannot be quantified or 
specifically described until the details 
of these arrangements are known. Early 
indications from operation studies 
suggest that the SWP's excess pumping 
and conveyance capacity available for 
wheeling with existing facilities and 
restrictions is small. The potential 
for wheeling would increase if SWP 
facilities were expanded. 

Probable impacts of wheeling arranged 
pursuant to Article 10(h) are outlined 
in Table 15 as they relate to probable 
impacts of other future actions. 

Further analysis of the environmental 
impacts of v^eeling may be found in the 
following future documents: 

The environmental impact report on 
installation and operation of addi- 
tional pumps proposed for the Banks 
Pumping Plant. 

The environmental statements being 
prepared by the U. S. Bureau of 
Reclamation concerning proposed water 
service contracts. 

The environmental documents the 
Department of Water Resources will 
prepare for a Delta water transfer 
facility. 

Any environmental document prepared in 
connection with new Delta standards 
that succeed those of Decision 1485. 



96 



The environmental document that will 
be prepared for the agreement 
negotiated pursuant to Article 10(h), 
should that agreement be determined to 
have significant environmental 
effects . 



Purchase of CVP Water by the SWP 

The negotiations required by 
Article 10(h) would address not only 
wheeling, but also purchase of CVP water 
by the SWP. With its reservoirs in the 
Sacramento Valley basin and on the 
Trinity River, the CVP has developed 
water supplies in excess of its existing 
contractual demands and in excess of its 
present Delta export capabilities. This 
excess supply includes the water the CVP 
would seek to have wheeled under 
arrangements negotiated pursuant to 
Article 10(h), and it includes the water 
the SWP would seek to buy. An indica- 
tion of the total amount of water that 
might be vAieeled or bought may be taken 
from the line labeled "Incremental 
Supply" in Exhibit B-1 of the proposed 
Agreement, which gives an annual figure 
of 405,000 acre-feet. 

The overall effect of a purchase of CVP 
water by the SWP would be to increase 
exports from the Delta. The effects of 
exports on the Delta were discussed in 
the preceding section, headed "Wheeling 
Arrangements". At least some of the 
increase in export would be sustained by 
increased drawdown at CVP reservoirs. 
Potential impacts of increased drawdown 
with the Proposed Action are discussed 
under "Environmental Consequences, 
Rivers and Reservoirs". No incremental 
impacts of water purchase can be 
quantified or specifically described 
until the water purchase arrangements 
resulting from the negotiation process 
pursuant to Article 10(h) are known. 
The water purchased by the SWP could 
probably be exported on a different 
schedule from that used to export water 
being wheeled for the CVP. Impacts 
would vary significantly according to 
the month in which project operations 
are changed. 



In the State Water Project service 
areas, no significant environmental 
impacts would be expected as a result of 
any water purchases by the SWP from the 
CVP with existing facilities. This is 
because the amount of water that could 
be purchased would likely be relatively 
small and serve only to maintain, and 
not expand, existing agricultural and 
urban uses. 

The probable impacts of water purchases 
such as may be arranged pursuant to 
Article 10(h) are outlined in Table 15 
as they relate to the probable impacts 
of other future actions. 

Potential environmental impacts of water 
purchases by the SWP from the CVP will 
be analyzed further when a wheeling and 
purchase contract has been negotiated. 



Removal of the Moratorium on 
New Water Service Contracts 

After the Coordinated Operation Agree- 
ment is signed, the Bureau of Reclama- 
tion plans to propose that the Secretary 
of the Interior lift a moratorium on the 
Bureau entering into additional long- 
term CVP water service contracts. The 
moratorium was administratively imposed 
by a previous Secretary of the Interior 
in 1979. The terras of the moratorium 
provided that it would be lifted when 
the responsibilities of the CVP toward 
water quality protection in the Delta 
had been clarified and the Bureau had 
conmitted itself to meet these responsi- 
bilities. The Delta water quality and 
outflow standards in Exhibit A of the 
proposed Agreement, plus the sharing 
formula contained therein, define the 
CVP's responsibilities toward Delta 
water quality protection. Signing the 
Agreement would commit the Bureau to 
meeting these responsibilities. 

The proposed Agreement quantifies the 
water supply of the CVP and removes some 
uncertainty regarding how much of that 
supply remains uncommitted. The CVP now 
has water service commitments totaling 
7.3 million acre-feet, and Exhibit B-2 



97 



of the proposed Agreement indicates that 
the CVP could supply as much as 8.3 mil- 
lion acre-feet through existing CVP 
facilities on a firm basis when "full 
development" is reached. Potential 
customers for the uncommitted 1.0 mil- 
lion acre-feet include the State Water 
Project and users in the Sacramento and 
San Joaquin valleys. 

Environmental impacts of new CVP water 
service contracts would depend on the 
location of the contractor, the amount 
of water involved, the season of water 
delivery, and many other factors. 
Table 15 outlines the probable impacts 
of new CVP water service contracts north 
and south of the Delta as they relate to 
the probable impacts of other future 
actions. More detailed environmental 
analysis of such impacts will be done 
when specific contracts are being 
considered. Such analyses will include 
fish and wildlife, endangered species, 
cultural resources, recreation, prime 
agricultural lands, floodplain manage- 
ment and wetland protection, socio- 
economic, drainage, subsidence and 
land-use changes. The Bureau has 
scheduled and budgeted environmental 
reviews for future water marketing 
activities in the following service 
areas: 

The Sacramento Sacramento Division , 
which provides water to Tehama-Colusa 
and Corning service areas. Tehama- 
Colusa service area, on the west side 
of the Sacramento River, extends from 
the middle of Tehama County to north- 
ern Yolo County. Of about 205,000 
irrigable acres in the service area, 
59,921 were irrigated in 1983. The 
Corning service area is in Tehama 
County, west of the Tehama-Colusa 
service area. Of about 38,423 irrig- 
able acres in the service area, 11,014 
were irrigated in 1983. 

The Delta Division , which is in the 
northern half of San Joaquin Valley 
along the San Joaquin River and west 
of it from Alameda and San Joaquin 
counties south to Fresno County. Of 



about 235,000 irrigable acres in the 
service area, 190,244 were irrigated 
in 1983. Municipal and industrial 
(M&I) uses in the Delta Division 
include about 78,000 acre-feet per 
year of water. Over 190,000 people 
are served, mainly in Contra Costa 
County. About 14,800 acre-feet of 
water is supplied annually for water- 
fowl management and gun clubs. 

' The West San Joaquin Division , vAiich 
is in the western portion of Fresno, 
Kings, and Merced counties. Of about 
633,000 irrigable acres in the service 
area, 492,322 were irrigated in 1983, 
About 11,600 acre- feet per year of 
water was delivered for Mi&I uses, 
serving about 24,500 people. 

The American River Division , v^ich is 
in Sacramento and eastern San Joaquin 
counties. There are about 416,000 
irrigable acres in the unit. Water 
could be delivered if Auburn Dam were 
completed. The Folsom Unit, in Sacra- 
mento, Placer, and El Dorado counties, 
mainly serves water for M&I use. Of 
about 29,500 irrigable acres, 2,606 
were irrigated in 1983. About 52,225 
acre-feet per year of water was deliv- 
ered for M&I use in 1983, serving 
about 284,240 people. By 2020, about 
135,000 acre-feet of water would be 
required annually for M&I uses. 

The Shasta Division , which is in 
Shasta and northern Tehama counties. 
Of about 449,000 irrigable acres in 
the service area, 254,360 were irri- 
gated in 1983. About 4,994 acre-feet 
of water is delivered annually for M&I 
uses, serving about 59,515 people. 

The Friant Division , which serves 
Fresno, Tulare, and Kern counties. Of 
about 928,000 irrigable acres in the 
service area, 695,113 were irrigated 
in 1983. Madera Canal serves Madera 
County. Of about 161,000 irrigable 
acres in the service area, 131,931 
were irrigated in 1983; 18,430 acre- 
feet of water is delivered annually 
for M&I uses, serving 229,459 people. 



98 



The Mid-Valley Canal service area , 
which is in the east side of the San 
Joaquin Valley from Merced County to 
Tulare and Kings counties. It has 
about three million irrigable acres 
planning for a Mid-Valley Canal to 
serve this area ended in 1979 because 
the water supply was no longer avail- 
able. The Mid-Valley area has been 
integrated into a larger study, the 
San Joaquin Conveyance Study. The 
service area for this study would 
include the east side of San Joaquin 
Valley from San Joaquin County to Kern 
County. 

Probable impacts of new CVP water 
service contracts as they relate to 
probable impacts of other future 
actions are outlined in Table 15. 



Mitigation Measures 
for Cumulative Impacts 

Various actions such as Decision 1485, 
Suisun Marsh facilities, and Department 
of Fish and Game stocking programs have 
benefited fish and wildlife in the 
Delta. Studies by State, Federal, and 
private groups have provided much infor- 
mation from which laws protecting fish 
and wildlife have been enacted. Today 
at least 30 State and Federal policies, 
as well as agency regulations, help pro- 
tect the Delta's environment. Physical 
facilities such as fish screens at CVP 
and SWP pumping plants have been rela- 
tively effective in salvaging fish from 
export water. Funds for protection of 
fish and wildlife resources from State, 
Federal, and local sources have exceeded 
$87 million for ecological studies and 
physical facilities. 

Mitigation measures for cumulative 
impacts due to future State, Federal, 
and local water development generally 
consist of: 

° Safeguards by laws, regulations, and 
water rights standards. 
Contracts. 



Physical measures. 

Studies and water management 

programs . 



Safeguards 

State and Federal laws that provide 
safeguards include: 

Area of Origin Law 
County of Origin Law 
Davis-Dolwig Act 
Delta Protection Act 
Burns-Porter Act 
Porter Cologne Act 

California Environmental Quality Act 
National Environmental Policy Act 
National Fish and Wildlife 
Coordination Act 
National Clean Water Act 
Provisions in Congressional Authori- 
zation of Federal Water Projects 

State and Federal regulatory agencies 
administering the laws include the State 
Water Resources Control Board, Regional 
Water Quality Control Boards, Environ- 
mental Protection Agency, and U. S. Army 
Corps of Engineers. 



Contracts 



Binding contracts are negotiated between 
project operators and various interests. 
The Department of Water Resources has 
executed contracts with several Delta 
water agencies that commit the Depart- 
ment to provide reliable water supplies 
and qualities under the Delta Protection 
Act. These contracts provide a further 
safeguard for Delta protection. The 
Department is continuing negotiations 
with other Delta interests. 

Contracts for management of fish and 
wildlife resources in the Bay and Delta 
estuary can be broadened as to scope and 
the participating agencies. Such con- 
tracts would specify mitigation measures 
identified by studies and negotiations. 



99 



The proposed agreement for coordinated 
operation of the State Water Project and 
the Central Valley Project would allo- 
cate available supplies and shortages 
between the projects after meeting 
in-basin obligations, including Delta 
water quality objectives. 



Physical Measures 

Potential physical mitigation measures 
for identified significant impacts are 
listed below. Specific measures could 
be incorporated in contracts. 

Fish — Hatchery construction, adjust- 
ment of reservoir releases, habitat 
modification, establishment of reser- 
voir fishery, fish screens and return 
systems, export curtailments, and fish 
stocking programs. 

Wildlife — Purchase of replacement 
lands, capture and removal of species, 
control fencing, escape devices; 
mitigation in Suisun Marsh as 
specified in the Environmental Impact 
Report and Plan of Protection. 

Socioeconomic — Payment of increased 
public services caused by project 
workforce . 

Cultural -- Avoidance or removal of 
identified cultural resources where 
possible; purchase of private property 
where necessary. 

Recreation — Construction of recrea- 
tional facilities. 

Soils and Vegetation — Reestablish- 
raent of native vegetation, erosion 
control techniques, replacement of 
soil and topography where possible. 



Transportation 
and railroads. 



-- Relocation of roads 



Utilities -- Relocation of utilities, 



Studies and 

Water Management Program 

Many of the specific needs for mitiga- 
tion are uncertain. Potential impacts 
requiring mitigation can be identified 
during studies. Objectives of the 
Interagency Ecological Study Program for 
the Sacramento-San Joaquin Estuary, 
funded in part by the State Water 
Project, are to: 

Improve understanding of the require- 
ments of fish and wildlife in the 
estuary. 

Develop design and operating criteria 
for the State Water Project and 
Central Valley Project for protection 
and enhancement of fish and wildlife. 

Monitor and evaluate project opera- 
tions. 

These studies provide a sound basis for 
mitigation measures. For example, the 
predation control studies in Clifton 
Court Forebay may reduce losses of 
Chinook salmon. 

The court decision requiring monitoring 
of Delta channels with the additional 
pumps also provides mitigation. Mitiga- 
tion for Delta agricultural needs will 
be identified through studies of the 
salt tolerance of corn. Continuation of 
programs to improve water management 
would provide mitigation by reducing the 
buildup rate of future upstream 
diversions and Delta exports. 



100 



REFERENCES CITED 

1 Department of Water Resources, Division of Planning. "State Operation and 
Management of the Central Valley Project". Reconnaissance Report. 1982. 

2 Environmental Defense Fund, Inc., vs. Rogers C.B. Morton, Secretary of the 
Interior, et al . ; U. S. District Court for Eastern District of California, 
Stipulation for Dismissal Without Prejudice; June 17, 1975. 

3 U. S. Department of the Interior news release, "Secretary Andrus Announces 
Interior Will Voluntarily Meet California Delta Water Quality Standards," 
January 3, 1979. 

4 State Water Resources Control Board. "Water Quality Control Plan, 
Sacramento-San Joaquin Delta and Suisun Marsh". 1978. p. VI-11. 

5 State Water Resources Control Board, Water Right Decision 1485, 1978, 
p. 14-15. 

6 Department of Water Resources. "Plan of Protection for the Suisun Marsh, 
Including Environmental Impact Report". Published Draft, 1983. 

7 Department of Water Resources. "The DWR Position on the Peripheral Canal and 
Other SB 200 Facilities" (booklet). 1981. 

8 Department of Water Resources. "Draft Environmental Impact Report, Agreement 
to Manage Fish and Wildlife Resources, Sacramento-San Joaquin Estuary". 1982. 
p. 90. 

9 Madrone Associates. "Delta Wildlife Habitat Protection and Restoration Plan", 
prepared for California Department of Fish and Game and U. S. Fish and Wildlife 
Service. 1980. p. 2-6. 

10 U. S. Army Corps of Engineers. "Draft Feasibility Report and Draft 
Environmental Impact Statement, Sacramento-San Joaquin Delta". 1982. 

11 T. L. Prichard, et al . "Relationship of Irrigation Water Salinity and Soil 
Water Salinity". California Agriculture 37:7 and 8. July-August 1982. 

p. 14. 

12 Department of Water Resources. "Benefit-Cost Analysis of the Proposed 
Peripheral Canal Project". Central District. 1982. p. 23. 

13 Madrone, op. cit., p. 2-9. 

14 Department of Water Resources. "Plan of Protection for the Suisun Marsh 
Including Environmental Impact Report". Central District. 1984. p. 42. 

15 Department of Water Resources. "San Joaquin Valley Post-Project Economic 
Impact, 1981". San Joaquin District. 1982. 



101 



16 Department of Water Resources. "Water Action Plan for the South Coastal Area", 
Southern District. 1981. p. 6. 

17 Department of Water Resources. "Final Environmental Statement/Environmental 
Impact Report, North Bay Aqueduct (Phase II Facilities), Solano County 
California". 1982. 



102 



INDEX 



Pages 



Affected Environraeat (Regional Setting) 

Bay-Delta Estuary 
. State Water Project Service Areas 
Central Valley Project Service Areas 
Rivers and Reservoir 

Agreements and Permits 

Articles of the Agreement (Summary) 
Exhibits of the Agreement (Summary) 
Accomplishments of the Agreement 

Alternatives 

Proposed Action 

No Action 

Modified Agreement 

No Coordination 

Conceptual Comparison (Proposed Action 

-vs- No Action) 
Environmental Comparison of Alternatives 

Amphibians and Reptiles 

Aquatic Invertebrates 

Archeology 



39-100 

42-55 
61-62 
64-68 
68-73 

Appendix A 

7-14 
14-15 
15-19 

21-38 

21 

21-23 
23-27 
27 

28 
34-37 

See Endangered Species 

52-54, Appendix D 

94, Appendix I 



Birds 



52-54, 59-61, 71, 73, 78 
Appendix D 



Central Valley Project, History and Purpose 

Clean Water Act - Section 404 

Climate 

Contract 

Consultation and Coordination 
Coordinated Operation Agreement 



Appendix F 

40 

See Coordinated Operation 
Agreement 

Appendix C 

Appendix A 



103 



Pages 



Cost 

Agriculture 

Municipal and Industrial 

Fish 

Cultural Resources 



46, 61, 64 

48, 62 
49 

94, Appendix I 



Economic Comparison 
Endangered Species 

Energy 

Environmental Commitments 

Environmental Consequences 

Delta-Bay Estuary 

State Water Project Service Areas 

Central Valley Project Service Areas 

Rivers and Reservoirs 

Cumulative and Growth Inducing Impacts 

Unavoidable Adverse Impacts 



36, 64 

52, 60, 61, 71, 73, 78, 
Table 6, 7, Appendix D 

82-83 

Appendix H 



55-61 

62-64 

68 

73-81 

94-97 

93 



Fish 

Salmon 
Shad 

Steelhead 
Striped Bass 

Sturgeon 

Fishing 

Floodplain Management 



34-36, 49, 51, 58-59, 69-81 

49, 69, 73 

49, 69-73 

24, 35, 36, 49-51, 57-58, 69, 

73 

49, 69 

See Recreation 

Appendix E 



Ground Water 



Seepage 

Growth Inducement 



69, 77 
94 



History 



Central Valley Project 
Prior Agreements 
State Water Project 



1 

2. 4 
2 



104 



Pages 



Hunting 



See Recreation 



Impacts 
Invertebrates, Aquatic 



See Environmental Consequences 
See Aquatic Invertebrates 



Literature Cited 



101 



Mammals 

Metropolitan Water District 

Mitigation Measures 

Direct Effects 
Cumulative Impacts 



51-52, 59-60, Table, 
Appendix D 

Figure 12 

99-100 

37-39 
Appendix U 



Negotiations 



4-5 



Operation Studies 



30-34, Appendix G 



Power 

Purpose and Need of Action 



82-83 
1-5 



Questions 



Appendix J 



Rare, Threatened, and Endangered Species 

Recreation 

Related Actions and Projects 

Reservoirs 

Auburn 

Clair Engle 

Folsom 

Oroville 

Shasta 

Whiskeytown 



52, 53-54, 60-61, 78, 80, 
Appendix D 

68, 71, 72, 73, 78, 79, 80 

83-93 



35, 71, 78-79, 81 

35, 73, 80, 81 

36, 72-73, 79-80, 81 
35, 68-69, 74-78, 81 
71 



10 5 



Pages 



Rivers 



American 

Feather 

Sacramento 

San Joaquin 
Trinity 



35, 36, 73, 81 

39, 72-73, 79-80, 81 

1, 35, 36, 50, 51, 68-71, 

74-78, 81 

35, 36, 48, 50, 51, 58, 59 

17, 78-79, 81, 90 



Sacramento-San Joaquin Delta 

San Francisco Bay 

Seepage 

Service Areas 

Central Valley Project 
State Water Project 

Sharing Formula 

State Water Resources Control Board 

Storage 

Suisun Bay 

Suisun Marsh 



See Affected Environment, 
Bay-Delta Estuary 

35, 42, 52-55, 58 

69-77 



64-68 
61-64 

5, 8-12, 17, 18-19, 21, 23-24 

16, 45, 47, 94, 96 

34, 77, 78, 80 

36, 42, 45, 50 

16, 24, 35, 45, 59-60, 84-86 



Temperature 



74-77, 78-79, 80, 81 



U. S. Fish and Wildlife Service 
Urban Uses 



25, 26 

See Water Quality - Municipal 
and Industrial Uses 



Waterfowl 

Water Purchases 

Water Quality 

Clean Water Act 

Delta Agriculture 

Fish 

Municipal and Industrial Uses 

Rivers 



See Wildlife 
12, 97 



Appendix F 

35, 36, 46-47, 55-56 

See Fish 

35, 36, 47-49, 56-57 

See Rivers 



106 



Water Service Contracts 

Water Supply 

Wetlands 

Wheeling 

Wildlife 



Pages 

18, 97-99 

52, 58, 12, Appendix G 

Appendix E 

12, 15, 19, 27, 96-97 

25-26, 51-52, 59-60 



107 



I 



Appendix A 



AGREEMENT BETWEEN THE UNITED STATES OF AMERICA AND THE 
DEPARTMENT OF WATER RESOURCES OF THE STATE OF CALIFORNIA 
FOR COORDINATED OPERATION OF THE CENTRAL VALLEY PROJECT 
AND THE STATE WATER PROJECT, USBR/DWR DRAFT 



APPENDIX A 



USBR/DWR DRAFT 

Rev. USER 05/20-1985 



AGREEMENT 
BETWEEN 
THE UNITED STATES OF AMERICA 
AND 
THE DEPARTMENT OF WATER RESOURCES OF 
THE STATE OF CALIFORNIA 
FOR 
COORDINATED OPERATION 
OF THE 
CENTRAL VALLEY PROJECT 
AND THE 
STATE WATER PROJECT 



(This coordination agreement suspends the agreement of 
May 16, 1960, between the United States and the State of 
California. ) 



United States of America 
Department of the Interior 
Bureau of Reclamation 
Central Valley Project 
California 



State of California 
The Resources Agency 
Department of Water 

Resources 
State Water Project 



No. 14-06-200-8363 



AGREEMENT BETWEEN 
THE UNITED STATES OF AMERICA I 

AND 
THE DEPARTMENT OF WATER RESOURCES OF 
THE STATE OF CALIFORNIA 
FOR COORDINATED OPERATION OF THE 
CENTRAL VALLEY PROJECT AND THE STATE WATER PROJECT 



Table of Contents 

Article Title Page 

1 Preamble 1 

2 Explanatory Recitals 1 

3 Definitions 4 

4 Term of Agreement 7 

5 Facilities 7 

6 Coordination of Operations 8 

7 Forecasting 12 

8 Water Measurement Responsibilities 13 

9 Reduction in United States and 13 
State Exports 

10 Exchanges, Conveyance, and Purchases 14 
of Water Supply 

11 Delta Standards 20 

12 Monitoring 22 

13 Records 22 

14 Periodic Review 23 

15 Relation to Agreement of 25 
May 16, 1960 

16 New Facilities 25 



Table of Contents (Continued) 
Article Title Page 

17 Project Service Areas 26 

18 Third Party Rights Unaffected 26 

19 Effect of Waiver of Breach 26 

20 Equal Employment Opportunities 26 

21 Contingent Provisions 29 

22 Officials Not to Benefit 29 
Signature Clause 30 

Exhibits 

A Standards for the Sacramento-San Joaquin 

Delta 

B-1 Central Valley Project and State Water 

Project Annual Supplies 

B-2 Central Valley Project and State Water 

Project Full Development Annual Supplies 

C Monitoring Locations 

D Exchange Procedure to Provide D-1485 Condition 3 

Replacement Water (Article 10b of COA) 

E Water Shortage and Apportionment 



AGREEMENT BETWEEN 
THE UNITED STATES OF AMERICA 
AND 
THE DEPARTMENT OF WATER RESOURSES OF 
THE STATE OF CALIFORNIA 
FOR COORDINATED OPERATION OF THE 
CENTRAL VALLEY PROJECT AND THE STATE WATER PROJECT 



1. THIS AGREEMENT, made the 



day of , 198 , pursuant to the Act of 

Congress approved , 

P.L. , and pursuant to the California 

Central Valley Project Act, which is Part 3, Division 6 
(commencing at Section 11100) of the California Water Code, 
and the California Water Resources Development Bond Act, 
Chapter 8, Part 6, Division 6 (commencing at Section 12930) 
of the California Water Code, between THE UNITED STATES OF 
AMERICA, herein called the United States, acting through the 
Bureau of Reclamation, Department of the Interior, represented 
by the contracting officer executing this agreement, and THE 
DEPARTMENT OF WATER RESOURCES OF THE STATE OF CALIFORNIA, 
herein called the State, represented by the director of Water 
Resources. 

EXPLANATORY RECITALS 
2. The United States has under construction and 
is operating the Central Valley Project, California, for the 



Articles 1 - 2 — 



development, conservation, control, and utilization of water 
resources in California. 

The State has under construction and is operating initial 
facilities of the State Water Resources Development System, 
herein called the State Water Project, for the development, 
conservation, control, and utilization of water resources in 
California. 

The United States and the State entered into an agree- 
ment on May 16, 1960, Article 16 of which recognizes the need 
for criteria for the coordinated operation of the Central 
Valley Project and the State Water Project. 

Certain basic assumptions of that agreement require 
modification in light of subsequent developments and changes 
in the two projects. 

The United States and the State had prepared a May 13, 
1971, Draft Agreement which would have supplemented the 
Agreement of May 16, 1960. 

The United States and the State have in the past 
been operating under annual letter agreements implementing 
the May 13, 1971, Draft Agreement. 

The United States and the State by entering into 
this agreement will suspend the Agreement of May 16, 1960; 
but it is recognized that the legal positions of the parties 
regarding any interpretation of the terms of said agreement 
are preserved. 

2 — Article 2 — 



The United States and the State will observe reservoir 
operational criteria prescribed by the United States Corps of 
Engineers to minimize flood hazards. 

The United States and the State each plans to meet 
all requirements and objectives of its project and to 
coordinate the operation of their projects so as not to 
adversely affect the rights of other parties and to conserve 
water . 

The State and the United States intend to build addi- 
tional water storage and transportation facilities. 

Both the United States and the State have, pursuant 
to applications filed with the State Water Resources Control 
Board (formerly State Water Rights Board), received permits 
for appropriation of unappropriated water in furtherance of 
their respective projects. 

It is in the best interest of the United States and 
the State to agree on the use of water rights as set forth in 
this agreement rather than litigate such uses as between the 
two projects and potentially all other water users in the 
Central Valley of California. 

Both the State and the United States are dedicated 
to utilizing their existing and future water conservation 



— Article 2 — 



facilities so as to provide the maximuin benefits to the 
people of California and the Nation and believe that through 
the coordinated and cooperative operation of State and 
Federal facilities, these benefits can be maximized. 
NOW, THEREFORE, it is agreed: 

DEFINITIONS 
3. When used in this agreement, the following shall 
have the meanings hereinafter set forth: 

(a) "Sacramento Valley inbasin uses" are legal uses of 
water in the Sacramento Basin including the water required under 
the provisions of Exhibit A. 

(b) "Balanced water conditions" are periods 

when it is agreed that releases from upstream reservoirs plus 
unregulated flow approximately equal the water supply needed 
to meet Sacramento Valley inbasin uses, plus exports. 

(c) "Excess water conditions" are periods when 
it is agreed that releases from upstream reservoirs plus 
unregulated flow exceed Sacramento Valley inbasin uses, 
plus exports. 

(d) "United States storage withdrawal" is the 

sum of "Whiskeytown storage withdrawal" which is the positive 
daily mean flow computed by subtracting the daily mean local 
inflow to Whiskeytown Lake (total inflow excluding the flow 
through the Judge Francis Carr Powerplant) from the sum of 
the daily mean diversions from (i) Whiskeytown Lake to Spring 
Creek Powerplant, (ii) the Whiskeytown Dam releases to Clear 

4 — Articles 2 - 3 — 



Creek, and (iii) measured water deliveries from Whiskeytown 
Lake; and the positive sum of: 

(1) "Shasta storage withdrawal" which is 
the daily mean flow computed by subtracting the sum of 

(i) the daily mean inflow into Shasta Lake and (ii) the daily 
mean discharge from Spring Creek Powerplant from the sum of 
(i) the Keswick Dam releases to the Sacramento River and 
(ii) measured water deliveries from Shasta and Keswick Lakes; 
and 

(2) "Folsom storage withdrawal" which is 
the daily mean flow computed by subtracting the daily mean 
inflow into Folsom Lake from the sum of (i) Nimbus Dam 
releases to the American River, (ii) Nimbus Dam diversions to 
Folsom South Canal, and (iii) measured water deliveries from 
Folsom Lake and Nimbus Lake. 

(e) "State storage withdrawal" is the value 
calculated in 3(e)(1) except when specifically declared by 
the State that Upper Feather storage withdrawals are being 
made in which case "State storage withdrawal" is the sum of 
3(e) (1) and (2). 

(1) "Oroville Complex storage withdrawal" 
is the positive daily mean flow computed by subtracting the 
sum of the daily mean inflow into Lake Oroville and the daily 
mean discharge from Kelly Ridge Powerplant from the sum of the 
daily mean diversions at or into the following facilities: 

5 — Article 3 — 



Palermo Canal, Thermalito Diversion Dam to Feather River, 
Thermalito Diversion Dam to Hatchery, Diversion Structures 
for Butte County, Thermalito Irrigation District Diversion 
Structure, Richvale Canal, Western Canal, Pacific Gas and 
Electric Company's Lateral, Sutter Butte Canal, and the 
Thermalito Afterbay Outlet to Feather River. 

(2) "Upper Feather River storage withdrawal" 
is the positive daily mean flow computed by subtracting the 
sum of the daily mean flow into Lake Davis and Antelope 
Reservoir from the sum of the daily mean releases from these 
reservoirs . 

(f) "Export" means diversions by the United States and 
the State through export facilities specified in subarticle 5(b), 

(g) "United States stored water" is the net 
increase in daily storage in Shasta Lake and Folsom Lake. 

(h) "State stored water" is the net increase 
in daily storage in Lake Oroville and, when declared by the 
State, the net increase in daily storage in the Upper Feather 
River reservoirs, 

(i) "Delta" means the Sacramento-San Joaquin 
Delta as described in California Water Code §12220 (Stats. 
1959, C. 1766, p. 4249, § 1). 

(j) "New Delta standards" are any Delta standards 
different from those set forth in Exhibit A. 



— Article 3 — 



TERM OF AGREEMENT 

4. This agreement shall remain in full force and 
effect until terminated either by the mutual consent of the 
parties or as provided in subarticles 10(h), or 14(b). 

FACILITIES 

5. This agreement recognizes the following facilities 
as presently existing: 

(a) Reservoirs: 

United States State 



Shasta Lake 
Keswick Reservoir 
Clair Engle Lake 
Lewiston Lake 

Whiskeytown Lake 

Folsom Lake 



Lake Natoma 

San Luis Reservoir 
(Joint) 

O'Neill Forebay 
(Joint) 



Millerton Lake 
New Melones 



Lake Oroville 

Thermalito Forebay 

Thermalito Afterbay 

Thermalito Diversion 
Dam Reservoir 

San Luis Reservoir 
(Joint) 

O'Neill Forebay 
(Joint) 

Lake Davis 

Antelope Lake 



Lake Del Valle 
Pyramid Lake 
Castaic Lake 
Silverwood Lake 
Lake Perris 



Articles 4 - 5 — 



(b) Export facilities: 

United States State 

Contra Costa Harvey 0. Banks Delta 

Pumping Plant #1 Pumping Plant, 

including Clifton 
Court Forebay 

Tracy Pumping Plant 

COORDINATION OF OPERATIONS 
6. (a) This agreement was negotiated on the basis of 
annual supplies reflected in Exhibit B. It is agreed that: 

(1) The computations described in this 
article shall be the basis upon which the United States 

and the State shall coordinate the operations of the Central 
Valley Project and the State Water Project facilities specified 
in Article 5 in order to meet Sacramento Valley inbasin 
uses and maintain the respective annual water supplies 
specified in Exhibit B-1, or as that exhibit is revised 
in accordance with subarticle 6(a)(3). 

(2) Nothing in this agreement shall constrain 
either party from moving toward full utilization of its 
facilities at any time. 

(3) As either party proceeds toward the full 
utilization of its project, any changes in the underlying 
assumptions with respect to the development of the two 
projects and the demands for water from each project will be 
reflected by recomputing the annual water supplies specified 

8 — Articles 5 - 6 — 



in Exhibits B-1 and B-2 in accordance with the provisions of 
subarticle 14(a). The methodology described in the document 
entitled "Technical Report on Determination of Annual Water 
Supplies for Central Valley Project and State Water Project," 
dated March 1984 will be used to recompute the annual water 
supplies and to revise, if necessary, the factors and procedures 
contained in this article. 

(b) Determination of Sacramento Valley Inbasin 
Use of Storage Withdrawals and Unstored Water for Export ; 
During period of balanced water conditions, daily computation 
shall be made to determine the difference between (i) the sum 
of the United States and State storage withdrawals adjusted 
for time of travel to the export facilities specified in 
subarticle 5(b), and (ii) the sum of the United States and 
State exports. If total storage withdrawals exceed total 
exports, the difference represents Sacramento Valley inbasin 
use of storage withdrawals. If total exports exceed storage 
withdrawals, the difference represents unstored water for 
export. 

(c) Sharing of Responsibility for Meeting Sacramento 
Valley Inbasin use With Storage Withdrawals During Balanced 
Water Conditions ; Each party's responsibility for making 
available storage withdrawals to meet Sacramento Valley 



--Article 6 — 



inbasin use of storage withdrawals shall be determined by 
multiplying the total Sacramento Valley inbasin use of 
storage withdrawals by the following percentages: 
United States State 

75 25 

(d ) Sharing of Responsibility During Balanced 
Water Conditions When Unstored Water for Export is Available : 
Each party's responsibility to meet Sacramento Valley inbasin 
use and exports shall be determined by: 

(1) Allocating the sum of United States 
stored water, State stored water and the unstored water 
for export by the following percentages: 

United States State 

55 45 

(2) If the daily sum of United States stored 
water and unstored water for export is greater than the 
United States share as allocated in 6(d)(1), then the United 
States is obligated, except when either subarticle 6(h) or 
6(i) is in effect, to provide water to the extent that its 
daily sum is greater than its allocated share. 

(3) If the daily sum of United States stored 
water and the unstored water for export is less than its 
share as allocated in 6(d)(1) then the State is obligated, 
except when either subarticle 6(h) or 6(i) is in effect, to 



10 —Article 6~ 



provide water to the extent that the State's daily sum of 
State stored water and unstored water used for export is 
greater than its allocated share. 

(e ) Accounting of Accumulated Responsibilities : 
During balanced conditions, except when either sub- 
article 6(h) or 6(i) is in effect, the daily obligation as 
defined in subarticle 6(c) or 6(d) shall be accumulated. The 
accumulation in effect when balanced conditions end shall 
remain in force and resume when balanced conditions are again 
declared. At the request of either party, the accumulation 
will be reduced or eliminated within a reasonable time. 
Otherwise, the accumulation shall continue until the agency 
that has the positive accumulation (has released more water 
than its defined responsibility) goes into a flood control 
operation. A flood control operation occurs when the actual 
storage exceeds the defined flood control permissible storage 
at Oroville Reservoir for the State or Shasta Reservoir for 
the United States. The flood control operation at Folsom 
Reservoir will not affect this provision because of its 
limited conservation storage. 

(f ) Changes in Sacramento Valley Inbasin Use 
During Balanced Conditions ; If the Sacramento Valley inbasin 
use changes, upstream reservoir releases and/or exports will 
be modified based on the current accumulation identified in 
subarticle 6(e) and/or the daily share of responsibility 
computed in subarticles 6(c) and 6(d). 

11 — Article 6 — 



(g ) Responsibilities During Excess Water 
Conditions ; During excess water conditions each party has 
the responsibility to export and store as much water as 
possible within its physical and contractual limits. 

(h ) Availability of Storage Withdrawals to the 
Other Party ; Unless otherwise agreed, whenever a party's 
storage withdrawal available for export is greater than its 
export capability, the difference shall be available for 
export by the other party without affecting either party's 
future responsibility for providing storage withdrawals to 
meet Sacramento Valley inbasin use. 

( i ) Availability of Unstored Water for Export 
to the Other Party ; Unless otherwise agreed, whenever a 
party's share of unstored water for export exceeds its 
exports, the unusable portion is available for export by the 
other party without affecting either party's daily sum of 
stored water. 

FORECASTING 
7. Upon request, each party shall prepare and fur- 
nish to the other a forecast of its proposed operation 
related to the facilities specified in Article 5. The 
forecast shall indicate the flow available for export, 
storage withdrawals, and Sacramento Valley inbasin use. The 
forecasts shall be prepared and exchanged so as to allow 
sufficient time for the preparation of consolidated forecasts. 

12 — Article 6-7 



WATER MEASUREMENT RESPONSIBILITIES 
8. The United States and the State, each at its 
own expense, shall install and maintain measuring and record- 
ing devices at its facilities specified in Article 5. 

(a) Each party shall measure or compute and 
record daily, or at such other intervals as may be agreed 
upon, and provide to the other party the rates and quantities 
of water that will show the (1) estimated inflow to its 
reservoirs, (2) net releases from its reservoirs, (3) stage 
and change in storage of its reservoirs, (4) net amount of 
evaporation at its reservoirs, (5) diversions through its 
export facilities, and (6) its storage withdrawals. 

(b) The measuring and recording devices shall 

be examined, tested, and serviced regularly to assure their 
accuracy. At any reasonable time either party may inspect 
the measuring and recording devices of the other party. 
Immediate action shall be taken to correct any deficiencies 
noted in such inspections. Accuracy in measurements of 
export diversions and releases from reservoirs shall be 
within commonly accepted engineering standards. All computa- 
tions and correlations shall be calculated in a manner 
acceptable to both parties. 

REDUCTION IN UNITED STATES AND STATE EXPORTS 
9. If any forecast indicates that either the United 
States or the State, or both, will be unable to meet the 
anticipated demands of its water users during the balance of 

13 Article 8 - 9 — 



the calendar year, representatives of the United States and 
the State shall confer on possible procedures for making 
joint operational changes to minimize the shortage. If 
agreement cannot be reached on a joint procedure for minimiz- 
ing the threatened shortage, the United States and the State 
each shall be entitled to export the amount of water avail- 
able to it according to calculations made pursuant to 
Article 6, and each party shall assess against its users such 
reductions as it deems necessary or appropriate. 

EXCHANGES, CONVEYANCE, AND PURCHASES OF WATER SUPPLY 
10. (a) Either party may make use of its facilities 
available to the other party for pumping and conveyance of 
water by written agreement. 

(b) To the extent that operational constraints 
are imposed on the Central Valley Project by Exhibit A to 
minimize diversions of young striped bass from the Delta 
during May and June, which reduce Central Valley Project 
exports, the State will transport up to 195,000 acre-feet of 
Central Valley Project water through the California Aqueduct 
Reaches 1, 2A, and 2B no later than April 30 of the following 
year by direct diversion or by rediversion of stored Central 
Valley Project water at times that diversions do not reduce 
State Water Project yield. 

The State agrees to transport this water subject 
to the following: 

14 — Article 9 - 10 — 



(1) The United States will supply power 
according to Exhibit D; 

(2) During critical water supply years, as 
defined by D-1485, the State shall pump the water during 
Central Valley Project off-peak hours (10:01 p.m. to 6:59 
a.m. Monday through Saturday and all day Sunday and national 
holidays ) ; 

(3) In all other water supply years, to the 
extent possible as determined by the State, pumping of this 
water shall be provided during Central Valley Project off-peak 
hours; 

(4) The United States shall reimburse the 
State for incremental costs for pumping Central Valley 
Project water through the facilities specified in this 
subarticle. Incremental costs are those costs which if not 
reimbursed by the United States would otherwise cause 
increased charges to State Water Project water contractors 
over what they would have been charged if the State had not 
conveyed Central Valley Project water pursuant to this 
agreement, provided that the United States shall not be 
responsible for payment for any additional power demand 
charges that may result from pumping Central Valley Project 
water pursuant to subarticle 10(b). At present, the only 
incremental costs identified by the State are the replacement 
portions of the minimum and variable components of both the 
Delta Water Charge and Transportation Charge, as defined in 

15 —Article 10 — 



the November 4, 1960, State Water Supply Contract with The 
Metropolitan Water District of Southern California, as it now 
exists and may hereafter be amended. Incremental costs in 1985 
amounted to $0.21 per acre-foot of water conveyed. 

(c) The State agrees to give priority to the United 
States to convey Central Valley Project water for scheduled 
or unscheduled maintenance and unforeseen outages of the 
Central Valley Project, from the Delta to O'Neill Forebay, 
not covered in subarticles 10(b) and 10(d), through the 
California Aqueduct Reaches 1, 2A, and 2B facilities at times 
that such conveyance does not reduce use of the State's 
facilities for the benefit of the State's long-term water 
supply contractors subject to the following: 

(1) The United States will supply the power 
required to pump Central Valley Project water through the 
Harvey 0. Banks Delta Pumping Plant; 

(2) The State will be reimbursed for each of 
the following charges expressed as a unit rate and applied to 
each acre-foot of water conveyed. These charges will 

equal the sum of the components of the water charges for 
California Aqueduct Reaches 1, 2A, and 23 as defined in the 
State Water Supply Contract with the Metropolitan Water 
District of Southern California, dated November 4, 1960, as 
it now exists and may hereafter be amended. 



16 — Article 10 — 



(i) The capital component of the trans- 
portation charge. 

(ii) The minimum component of the 
transportation charge. 

(iii) The replacement portion of the 
variable component of the transportation charge. 

(iv) The capital component of the Delta 
water charge. 

(v) The minimum component of the Delta 
water charge. 

These charges for 1985 total $8.44 per 
acre-foot of water conveyed. 

(d) In consideration for the conveyance of State 
Water Project water for scheduled or unscheduled maintenance 
and unforeseen outages from the Delta to O'Neill Forebay 
through Central Valley Project facilities, the State will 
convey for the United States an equal quantity of Central 
Valley Project water measured in acre-feet through its 
facilities at no charge; Provided , that such conveyance of 
Central Valley Project water shall be accomplished, if 
possible, within 12 months from the date conveyance of State 
Water Project water was completed. Each agency shall be 
responsible for supplying the power required to pump its water, 



17 — ^Article 10 — 



(e) The State, in an annual letter to the United 
States, will transmit the charges referred to in subarticles 
10(b)(2) and 10(c)(2) above based upon the cost components 
listed therein. 

(f) The State will submit invoices to the United 
States on or before June 30 of the year following the year in 
which the wheeling occurs. The United States will make 
payment within 30 days after receipt of such invoice. 

(g) Prior to December 31 of the fifth full year 
following the execution of this agreement, the parties will 
agree upon the amount and value of the services each project 
has provided to the other project prior to the execution of 
this agreement and will agree upon the manner in which any 
imbalance is to be resolved. This subarticle shall not 
apply to services provided under a separate written agreement. 

(h) (1) The parties shall promptly commence 
negotiating a contract for the conveyance and purchase of 
Central Valley Project water to assist each party in making 
more efficient use of the water project facilities and water 
supplies contemplated in this agreement. The terms and 
conditions of said contract shall be no less favorable to 
either party than the terms and conditions either party would 
make available to their respective long-term contractors, 
except as specified by this subarticle. 



18 — Article 10 — 



(2) The contract referred to in subarticle 
10(h)(1) shall provide for, among other things, the sale of 
Central Valley Project water to the State for use by State 
Water Project contractors on the following conditions: 

(i) When the Central Valley Project 
water sold to the State is needed by existing or new long-term 
Central Valley Project contractors, it shall be recalled by 
the United States for such contractors; 

(ii) The United States shall impose 
deficiencies on water purchased by the State in a manner 
consistent with Exhibit E. 

(3) The contract referred to in subarticle 
10(h)(1) shall further provide for, among other things, the 
United States purchase of State Water Project conveyance 
service for transport of Central Valley Project water to 
Central Valley Project contractors on the following conditions: 

(i) The State shall transport Central 
Valley Project water for the United States up to the amount 
of Central Valley Project water made available to the State 
for purchase each year on the same priority as water transported 
for State Water Project long-term contractors; 

(ii) In addition, the United States shall have 
the first right to purchase all conveyance services that are 
in excess of the services being used to transport water 



19 — Article 10 — 



developed or purchased by the State or the State Water 
Project contractors. The conveyance of Central Valley 
Project water shall not diminish deliveries or increase costs 
of water supplies developed or purchased by the State or the 
State Water Project contractors. 

(4) The parties recognize that to fully 
impleinent this agreement, the parties may be required to seek 
amendments to existing water rights permits or additional 
water rights permits for, (i) an additional point of diversion 
and rediversion at the State's Harvey 0. Banks Delta Pumping 
Plant and the United States Tracy Pumping Plant; and (ii) 
consolidation and expansion of place of use. The State 

shall support the petition of the United States. 

(5) At any time after December 31, 1988, if 
either party shall not have received all of the amendments or 
permits described in subarticle 10(h)(4) and which contain 
conditions satisfactory to that party, then that party may 
terminate this agreement on 180 days written notice, or 
utilize the provisions of subarticle 14(b)(2) to seek a 
resolution of its concerns. 

DELTA STANDARDS 
11. (a) The Central Valley Project and the State 
Water Project will be operated in conformity with the Delta 
standards in Exhibit A. Should the State Water Resources 



20 —Article 10 - 11 — 



Control Board establish new Delta standards, and the United 
States determines that operation of the Central Valley 
Project in conformity with the new Delta standards is not 
inconsistent with Congressional directives the parties shall 
amend Exhibit A to conform with the new Delta standards and 
amend this agreement to the extent necessary to provide for 
continued operation of both projects to accomplish the 
purposes of this agreement. 

(b) Should the United States determine that the new 
Delta standards are inconsistent with Congressional directives 
then the United States shall promptly request the Department 
of Justice to bring an action for the purpose of determining 
the applicability of the new Delta standards to the Central 
Valley Project. 

(c) The United States reserves the right to seek, 
at any time, the enactment of legislation regarding the 
operation of the Central Valley Project, including compliance 
with new Delta standards, which may supersede any final court 
decisions addressed in subarticle 11(b). 

(d) The parties do not intend by this agreement to 
confer any additional authority upon either the Secretary of 
the Interior or the State Water Resources Control Board 
beyond that derived from applicable statutory and decisional 
law. 



21 —Article 11 



MONITORING 

12. (a) The United States and the State recognize 
that certain monitoring activities must be done to ensure 
compliance with the Delta standards specified in Exhibit A. 
The necessary monitoring activities are specified in 
Exhibit C. The United States and the State agree to share 
equally the cost of those monitoring activities, including 
the analysis of the collected data. 

(b) Exhibit C will be amended, if necessary, 

to ensure compliance with any Delta standards different from 
those set forth in Exhibit A which are applicable to the 
United States pursuant to Article 11. 

(c) The parties agree that additional data must 
be collected and processed to determine the effects of the 
projects on the Delta and San Francisco Bay. Monitoring in 
addition to that specified in Exhibit C and the performance 
of Delta water quality studies will be covered by separate 
agreements. 

RECORDS 

13. Subject to applicable laws and regulations, the 
United States and the State shall have full access at all 
reasonable times to the books and records of the other party 
insofar as they pertain to this agreement, with the right to 
make copies thereof. 



22 Articles 12 - 13 



PERIODIC REVIEW 
14. (a) Prior to December 31 of the fifth full year 
following execution of this agreement, and before December 31 
of each fifth year thereafter, or more frequently if so 
requested by either party, the United States and the State 
jointly shall review the operations of both projects. The 
parties shall (1) compare the relative success which each 
party has had in meeting its objectives, (2) review operation 
studies supporting this agreement, including, but not limited 
to, the assumptions contained therein, and (3) assess the 
influence of the factors and procedures of Article 6 in 
meeting each party's future objectives. The parties shall 
agree upon revisions, if any, of the factors and procedures 
in Article 6, Exhibits B and D, and the Operation Study used 
to develop Exhibit B. 

(b) (1) If the parties fail to enter into the 
contract referred to in subarticle 10(h)(1) by December 31, 
1988, either party may give written Notice of Negotiation to 
the other party. Within 30 days of such notice, each party 
shall designate one member of an Advisory Board to which that 
problem shall be referred. The members designated by the 
parties shall choose a third member who shall act as chairperson. 
The Board shall report its unanimous recommendation to both 
parties with respect to all terms and conditions to be 



23 Article 14 — 



included in said contract at a date not later than 12 months 
from the date of the Notice of Negotiation. The parties 
shall inunediately implement that recommendation. If the 
Board fails to made a unanimous recommendation within the 
12-month period, either party may unilaterally terminate 
this agreement. 

(2) If the parties are unable to agree on 
changes to this agreement, or either party fails to receive 
all of the amendments or permits described in Article 10(h)(4), 
either party may give written Notice of Negotiation. If 
agreement satisfactory to both parties has not been reached 
within 12 months of such Notice, each party shall designate 
within 30 days one member of an Advisory Board to which the 
problem shall be referred. The members designated by the 
parties shall choose a third member who shall act as 
chairperson. The Board shall report its unanimous 
recommendations to both parties at a date not later than 24 
months from the date of the Notice of Negotiation and the 
parties shall amend this agreement and immediately begin to 
operate in accordance with said recommendations. If the 
Board fails to make unanimous recommendations within the 
24-month period, either party may unilaterally terminate this 
agreement. 



24 — Article 14 



RELATION TO AGREEMENT OF MAY 16 > 1960 

15. This agreement suspends the Agreement of May 16, 
1960, and said Agreement of May 16, 1960, shall be of no 
force and effect whatsoever so long as this agreement remains 
in force. Should this agreement be terminated for any 
purpose, the Agreement of May 16, 1960, shall automatically 
become effective with both parties reserving their respective 
rights regarding the interpretation of the provisions thereof, 

NEW FACILITIES 

16. Any yield created by the construction of a new 
facility (not presently existing) by either party shall be 
attributed to the party constructing the new facility, and 
will require a review as provided for in Article 14. To the 
extent that water is exported outside the drainage of the 
Sacramento, Mokelumne, and Calaveras Rivers, the facilities 
used to convey such water shall be considered as export 
facilities for the purposes of Article 5. 



25 Articles 15 - 16 



PROJECT SERVICE AREAS 
17. The State and the United States agree that they 
will respect each others project service areas as defined by 
long-term contracts of either agency for the furnishing of 
water. 

THIRD PARTY RIGHTS UNAFFECTED 

18. Nothing in this agreement is intended to define, 
determine, limit, or affect the rights of third parties. 

EFFECT OF WAIVER OF BREACH 

19. The waiver of a breach of any of the provisions 

of this agreement shall not be deemed to be a waiver of any 
other provisions hereof or of a subsequent breach of such 
provisions. 

EQUAL EMPLOYMENT OPPORTUNITIES 

20. During the performance of this agreement, the 
State agrees as follows: 

(a) It will not discriminate against any employee 
or applicant for employment because of race, color, religion, 
sex, or national origin. It will take affirmative action to 
ensure that applicants are employed, and that employees are 
treated during employment without regard to their race, 
color, religion, sex, or national origin. Such action shall 
include, but not be limited to, the following: Employment, 



26 Articles 17 - 20 — 



upgrading, demotion, or transfer; recruiting or recruitment 
advertising; layoff or termination; rates of pay or other 
forms of compensation; and selection for training, including 
apprenticeship. It agrees to post in conspicuous places, 
available to employees and applicants for employment, notices 
to be provided by the contracting officer setting forth the 
provisions of this Equal Opportunity clause. 

(b) The State will, in all solicitations or 
advertisements for employees placed by or on its behalf, 
state that all qualified applicants will receive considera- 
tion for employment without regard to race, color, religion, 
sex, or national origin. 

(c) The State will send to each labor union 

or representative of workers with which it has a collective 
bargaining agreement or other contract or understanding a 
notice, to be provided by the agency contracting officer, 
advising the labor union or workers' representative of the 
State's commitments under this Equal Oportunity clause, and 
shall post copies of the notice in conspicuous places avail- 
able to employees and applicants for employment. 

(d) The State will comply with all provisions 
of Executive Order No. 11246 of September 24, 1965, as 
amended, and of the rules, regulations, and relevant orders 
of the Secretary of Labor. 



27 — Article 20 — 



(e) The State will furnish all information and 
reports required by said Executive Order, and by the rules, 
regulations, and orders of the Secretary of Labor, or pursuant 
thereto, and will permit access to its books, records, and 
accounts by the Bureau of Reclamation and the Secretary of 
Labor for purposes of investigation to ascertain compliance 
with such rules, regulations, and orders. 

(f) In the event of the State's noncompliance 
with the Equal Opportunity clause of this contract or with 
any of the said rules, regulations, or orders, this contract 
may be canceled, terminated, or suspended in whole or in 
part, and it may be declared ineligible for further Government 
contracts in accordance with procedures authorized in said 
Executive Order, and such other sanctions may be imposed and 
remedies invoked as provided in said Executive Order, or by 
rule, regulation, or order of the Secretary of Labor, or as 
otherwise provided by law. 

(g) The State will include the provisions of 
paragraphs (a) through (g) in every subcontract or purchase 
order unless exempted by rules, regulations, or orders of the 
Secretary of Labor issued pursuant to Section 204 of Executive 
Order No. 11246, so that such provisions will be binding upon 
each subcontractor or vendor. It will take such actions with 
respect to any subcontract or purchase order as the contracting 



28 —Article 20— 



officer may direct as a means of enforcing such provisions, 
including sanctions for noncompliance; Provided, however , 
That in the event the State becomes involved in, or is 
threatened with, litigation with a subcontractor or vendor as 
a result of such direction by the contracting officer it may 
request the United States to enter into such litigation to 
protect the interests of the United States. 

CONTINGENT PROVISIONS 

21. Performance by the State and the United States 
shall be contingent on: (1) the availability of Federal 
funds therefor; and (2) the availability of State funds 
therefor. 

OFFICIALS NOT TO BENEFIT 

22. (a) No member of or Delegate to Congress or Resident 
Commissioner shall be admitted to any share or part of this 
agreement or to any benefit that may arise herefrom. This 
restriction shall not be construed to extend to this agreement 
if made with a corporation for its general benefit. 

(b) No official of the State shall receive any 
benefit that may arise by reason of this agreement other 
than as a landowner within the Project and in the same manner 
as other landowners within the Project. 



29 — Articles 20 - 22 



IN WITNESS WHEREOF, the parties hereto, by their 
respective officers thereunto duly authorized, have duly 
executed this supplement on the day and year first herein- 
above written. 

THE UNITED STATES OF AMERICA 



By 



Regional Director, Mid-Pacific Region 
Bureau of Reclamation 



DEPARTMENT OF WATER RESOURSES OF 
THE STATE OF CALIFORNIA 



By 

Director 

Department of Water Resources 



30 Signature Clause 






O 

m 



u 












cd 












Q) 












t« 












M 












(0 <U 












T) -O 












d -H 












(U t-i 












iH O 


/-N 


/-^ 


.^s 


^■N 


y'-S 


(d iH 


^S 


»< 


B-S 


8-« 


»< 


O J3 


vO 


CM 


00 


u-> 


CN| 


O 


vO 


u-» 


si- 


•* 


-a- 


£ 


^^^ 


^^ 


^^ 


^^ 


^^ 


O iH 












<0 ' — 


o 


o 


m 


in 


m 


Ed 01 


■^ 


ON 


r~ 


v£> 


in 





CM 


r-l 


r-l 


■-I 


fH 


as 












!>^o 












(8 "^ 












Q rH 












<4-l C 












o n) 












J3 












M 4J 












(U 












r9 CO 












e M 












3 Q) 












Z 1-1 













o 
m 

CM 



o 
in 

CM 



o 

u-i 
CM 



(U 






iJ 


o 




(0 


u 


u-1 


a 




fH 





CM| 


• 


o 




u 


u 

M-l 


o 


3 


CJ 


c 




w 


Vi 





u 






o 


p 


u 


^ 




b 


iH 


JS 




w 


1-1 


0) 


l-l 


u 


^ 


5 



I CO >3- r~ O 
• • • • 

O rH rH CM 



m O Ul 

,H ^ CM ,-( 

. >, (U Q) 

Mi-I C C 



<: 

H 
M 
CQ 
M 



-Hi 

< 
H 

U 
O 






p en 

<: o 

H H 

t/3 Z 



o 









ta 

c 

B .H 

e 60 

•H S 
X 

C 









o 

IT) 

fH 4J 

to 

fH U 
•H O 
CO 14-1 

n 

0) 
C T3 

(1) t-l 

S o 

rH 

B x: 

3 CJ 

B 



^5 I 



ID 

XI 

o 

00 

u c 

0) -H 

-9 *^ 

B 3 
3 -O 
C 

<U 3 
J2 O 

*-» s: 
en 

4-1 

0) CO 

rH TJ 



M-l 

(U o 
XI 

CO 
4J fH 

CO Cd 

I £: 

(U 
4-1 

• c 

U -H 
CO 
0) c 

>< -H 
U T3 

Cd <u 

C -H 
Q) > 

fH O 

to U 



(0 

S! 

* 13 

O (U 
» 5« 



CO 

0) 

4-1 

c 

l-l 

Cd 
a 



a o 
to 

j= »< 

4J "^ 

CO C 

CO o 

0) -H 

r-H *J e 

Cd ? 



cd 

O 3 

a -o 



o 

x: 

CO 



CJ 



Cd 
Q 

Cd 

B -H 
3 -^ 
a bO 

13 ^ 

^5 



o 



cd 
Q 

C 
td 

B ^ 

a 00 
^5 






td 
a 

c 
td 

B .H 

2 ^ 
a 00 
•H a 

^5 



to cd 

B B fH 

Lj U (0 

O O O 

Z Z -H 

iJ 

4J • ' >^1-* 

0) X^ iH M >-l 

IS < PQ Q CJ 



00 

C >» 
•r^ fH 
C -H 

c Id 

c 
>^ Cd 
Cd oj 



S 



CO 

o 

a 



(1) 

00 
Cd C3 
U -H 

<u 
> u 



0) 



o 



0) 



o 



0) 


0) 


(U 


•o 


73 


T3 


•H 


•H 


•H 


V4 


Vi 


t^ 


O 


O 


O 


rH 


•H 


rH 


x: 


6 


6 



rH >, 
Cd 4J 
O tH 

•H > 

U <H 
4-1 4J 
O CJ 
0) 3 
fH -O 
M C 
O 
U 



Q 
U 
H 
CJ 
H 
H 
O 
Oi 
(3u 

CO 

u 
en 

o 



CJ 

M 
b 
U 

Z 

CQ 



0) 

Cd 

4J fH 

c 

M . 
O 

rH Z 
Cd 

C 4J 

Cd a 

CJ cd 

fH 

to (U 



CO 



o 

r-l Z 

to 

C 4J 

to c 
o to 

rH 

to P^ 



CO 


00 


CO 


00 


o 


c 


o 


c 


CJ 


•r^ 


u 


•r4 




o. 




Ciu 


to 


a 


CO 


a 


u 

4-1 


£ 


t-l 


eS 


c 




c 




o 


4J 


o 


4J 


CJ 


to 


u 


<: 



0) 
CO 



u 

CO 0) 

^ > 

M -H 
O pd 

C 
»-i -H 
(U 3 

4.) cr 

CO CO 

t-l 3 o 

o •-> 

x: 

CJ c 

O CO 
•H CO 
4-1 

^§ 



0) 








4J 








J£ 


>^ 






Ci 








«d 


CO 


rH 




Cd 








4J 


.o 


CO 


rH 


rH 








e 


(U 


c 


td 


PLi 








IH 


M 


to 


C 












o 


u 


td 


00 






h 


o x: 


f^ 




CJ 


c 






0) 


•ri 00 




4J 




•H 






0) > 


0) 3 


4-1 


CO 


to 


CU 






■C "^ 


tH O 


w 


0) 


u 


B 






4J pes 


iH rH 


3 


3 


o 


3 




•< 




CO CO 


o 




TJ 


&< 




fr> 


a o 


> 


CJ 


4J 


c 




ta 


rJ 


O 4J 


cu 
<*-> x: 


c 


to 


^ 




g 




c 


o o 


o 


0) 




td 


H 




o a 


c« 


4-1 


^ 


td 


u 


^ 


Z 


u CO 


>>o 


14-1 


td 


M 


H 


ec; 


« u 


u 


•H 


4-1 


rH 




O 


Cd 


a o 


•H 4J 


rH 


c 


0) 


4J 


M 


H 


a td 


CJ CO 


O 


M 


O 


td 




CO 
Cd 
3 


Cd CO 



C/3 



0) 
iJ o 

Q 



^: 



^ 9 at 

o a 

o X! <: 



«» m o 

I I r^ m CM 

t I • • • 

O ,-( CM 



-a- 
I m 
I • 

o 



I 00 t^ 
I U1 00 



o o 







~* 






^ 


lO 






>i 




u 


^ 


to 
o 


^ 


O 

4J 


■i 

s 


o 


tH 


m 


•-t 


fH 


u-> 


.H 


•H 


• 


•H 


U 


O 


t-l 


a 




D 


< 




<: 



(0 

U-l 

y 

o 
o 






M fH O 
"^ .H to 

-a- ^ 
• u V 

Q 



m 


m 


o 


lO 


1-1 


i-i 


(N 


.-t 


• 


« 


0) 


«> . 


00 


00 





d 


^ 


^ 


►^ 


^ ' 



u-i in m lo 

iH iH iH iH 


in in m m 

f-( .H .-1 CM 


• • • • 1 

00 00 00 00 


Aug. 
Aug. 
Aug. 
June 



H 



o 



o 

CO 

w 
a 



(0 rt 

as rH 

o o o 

4J • • >> -H 

S 33 pa Q o 



00 






c 


>^ 




t-t 


rH 




c 


•H 




c 


rt 




3 


Q 




cc: 


c 




>s 


n) 




<o 


^ 




T 


S 


CO 


<■ 


U-l 


o 


tH 


O 


■i 


a 


(U 


a 


3 


00 




a 


to 


c 


1-1 


u 


•H 


X 


01 




S 


^ 


u 
w 



CO 

o 



fS-H 



CO 

o 



J • • >> T-l 

(UjQi-imu mjar-ij-iu 



00 




00 


C >^ 




C f^ 


•H .-( 




T-l <-* 


C -H 




a th 


C CO 




C rt 


3 O 




3 O 


Pi 




ex! 


C 




c 


>, CO 




>% CO 


CO (U 




CO 0) 


T^ 


to 


r (0 


sr it-i 


o 


-* >*-i o 


,H o 




a <u a 


a 0) 


a 


3 OO 




3 00 


a CO 


c 


a CO c 


T-l U 


T-l 


T-l U T-l 


X <U 




X 01 


^^ 


a 


^^^ 









e 


•o 






CD 


0) 






Si 


0) 


CO 




u 


o 


u 






O X 


r-t 




U 0) 


M 0) 


0) 




b3 U 




Q 




O 


>. O 


0) 


C 


>. a 


^ 4J 


>^ J= 


CO 


1— ' 


T-l 


^ iJ 


£ 


•^ 4J 


CO 4-1 


tH 


4J 


to o 


T3 O 


CO U 




■o c 


a 


•O o 


to 




c 


U-l 


to 


c • 


CO T3 


V 


Oi 


CO "O 


0) O 


J= X 


,-t 


0) o 


a -^ 


4-1 0) 




a T-l 


t-l 


"O 


4J 


u 


VM 0) 


<« d 


o 


IM 0) 


o a 


O tH 


c 


o a 


0) 0) 


0) 3 


#t 


o; 0) 


60 J2 


OO o 


"O 


60 £ 


CO 4-> 


CO r-l 


o 


CO 4J 


kJ 


U 14-1 


T-l 


U 


0) M 


0) 4J 


u 


0) u 


> o 


> 3 


0) 


> o 


*»! U-, 


<! O 


a 


< IH 



OS 

H 



&< 



Q 
W 
H 
U 
U 
H 
O 
Oi 

cm 

U 

to 



z 

o 
1-1 

< 

u 
o 



M 

w 
z 
u 

CO 



■H >> 
CO 4-> 
tj T-l 

tH > 

U T-l 

4J 4J 

O O 

0) 3 

-H T) 

W G 

o 
u 







0) 






£ 






4-) Vl 






0) 






C3 > 






O -H 






pij 






4J 




-< 


c c 




H 


T-l T-l 


u 


>J 


O 3 


g 




(Xi cr 

CO 


H 




5N O 


^ 


§ 


0) -) 
to 


U 


U 


U c 


M 


H 


0) CO 


(Xi 


CO 


'^ trt 


o 


u 




<: 


s 





H 

O 

Pi 
O 



iH 


>% 


CO 


u 


O 


T-l 


T-l 


> 


u 


T-l 


u 


4J 


o 


O 


0) 


3 


.H 


"O 


W 


c 




o 




o 



0) 



a 
o 

ta 

3 
O 

c 



s -g 



kl 

0) 
H 



0) 

3 
iH 

0> 
M 



as 


4J 


O 


T-l 


tH 


> 


U 


T-l 


o 


4J 


Q) 


U 


.-1 


3 


u 


•o 




c 




o 




u 


d 




o 


Ul 




0) 


00 


> 


c 


T-l 


tH 


p:i 


T3 




c 


C 


5 


3 




cr 


tfl 


to 


CO 


o 


0) 


•-) 


M 




•o 


c 


.§ 


CO 
CO 


c 


0) 


CO 


J= 


tfl 


4-1 



(0 4J 



O 



"H >, 





u 


T-l 


14-1 


a 


O T-l 




•H 


> 


4J 




•H > 




u 


tH 


8 


c 


U T-l 




4J 


*J 


T-l 


4J U 




u 


«J 






V o 




0) 


3 


CO 


X 


0) 3 




.-1 


TD 


4J 


d) 


r-1 T3 




w 


c 


t-l 


•n 


Cd e 






o 
tJ 


cS 


^ 


ake 

er Co 




0) 








4J > 




j: 








C tH 




4J 








M Cti 


o 












e 


c 








to C 


M 


o 


u 






^ -H 


z 




0) 






U 3 


3 


4J 


> 






o cr 


< 


c 


tH 






gs 


cu 


tH 


Pi 


TJ 




CO 


P 




c 




0) -) 




(X 


c 


CO 




4-1 


CO 




T-l 


I-I 




CO C 


CO 


to 


3 


to 




:2 CO 


■< 


u 


V 


M 




CO 


PQ 


01 


CO 






j= 




c 


o 


to 




U 0) 


Q 


o 


•-) 


O- 




O J= 


u 


to 




O. 




T-4 4J 


Cu 


T-l 


c 


T-l 




4-> 


M 

pi 


^ 


CO 
CO 






.§ § 



CO 







cd CO 

^$ 

o e 
u B 



u 
ex 




in <Ti iri ~a- -a- en CM 



i-l 1-1 CM CO ^tf o m 
iH csi 



M 
O 

e 

O 

o in o lo o o o 
o iH rH ts en -3- 





o o o 
o o o 
o r^ m 


O O 
O O 
v£) CM 


o 
o 

0^ 


3 


*k •« »i 


•s #> 


#* 


•-) 


O r^ v£> 


CO m 


<N 


C 


O O O 
O O O 
O r~. in 


o o 
o o 

~3- vO 


o 
o 


1 


« fs •« 


*% Vs 


•s 


*-) 


-4- O CT. 


in m 


ro 



CO 



o o o 

o o o 

o o -* 

<f <r rH 



o o 
o o 
m fo 



o 
o 



I 



1 


m 


t-l 


fH 


, 


, 


Xi 


Vj 


<u 


n! 


l^ 


2 



o o o 
o o o 
o o o 



o o o 

o o o 

o o o 

CO CNI CN 



o 
o 
o 



o 
o 
o 



o 

CO 

< 

H 
M 
CO 

I— ( 



. 


o 


o o 


o 


c 


o 


o o 


o 


CO 


m 


m m 


in 


In 


#t 


•t *> 


«t 



I -H 



Cd 






M 
H 

M 

erf 

U 

n 



t-l 


1 


a 


IH 


CO 




CO 


0) 


o 


•a 


(1) 


i) 


a 


<u 


> 


u 




•o 


•H 


•H 


1 (U 


D. 


tn 




O 


•H 


iH 


c 




4-1 


<u 


c 


4-1 


a 


iH dJ 


<u 


o 


CO 


0) 




D. 


-H ^ 


x: 


OJ 


o 


•1-1 


•S 


3 


<: s 


4J 


•i-i 


D- 


o 


CO 




•o 














c 






1 


Q) 




o 0) 


o 




1 


V4 


CO 




w w 


a 


w 


CO 


(U 


o 







w 


(U 


iH 


4-1 


x; 




>^ S 


(U 


•H 


O 


OJ 


4J 




.H 


;-i 


o 


a-o 






•H W 


Vj 


c 


M 




c 




CO O 


o 


(U 


<u 


o 


0) 




Q C 


o 


•1-1 
o 


4-1 


4-1 


g 




C ' 


en 


•1-1 


•I-I 


•n 


4-) 




to T) 


(U 


IJ-I 




d) 


cu 




<u o 


3 


a) 


V4 


CO 


XI 




B -H 


r-i 


T3 


(0 


3 






H 


CO 




(U 




CO 




Uh <U 


> 


<u 


c 


(U 


cu 




O P. 




x; 


•H 


Xi 


3 






01 


4J 


iH 




iH 




0) dj 


x: 




N-^ 


o 


to 




60^ 


4-J 


o 




u 


> 


^•^ 


CO 4J 




4-1 


d 






g 


^ 


C 




OJ 


c 


(U 


(U t-l 


CO 


00^ 


o 


C 


o 


> o 


J= 


c 


(0 


•rl 


•H 


x: 


< M-l 


4J 


•H 


4J 


U 


s 


CO 



CO to 1-1 4J 

ga to iH 

C a (u 

o o C a 



a 


Z 


o 


i 


<r 


u^ 


4-1 
•H 


4-1 • 


• 


XI 


c 


>> 


>^ 


)-i 


0) XI 


1-1 


3 


M 


M 


)-l 


U 


3 <: 


« 


Crt 




Q 


Q 




to 


c 












4-1 


to 












tH 


J2 












(U 


4-1 












Q x: 














o 


CO 












>. to 


CO 












r-l 0) 


<u 












•H 


•H 












(0 M 














T3 O 


4J 












■4-1 


o 












0) 


c 












x: X 














4J (U 


G 












•a 


3 












4-1 C 


o 












O •H 


x: 

CO 












(U 3 














60 O 


"O 












to M 


o 












1-1 14-1 


•H 












(U 4J 


U 












> 3 


0) 












< O 


a 













<0 to iH 

gi to 

C o 

O O Vj -H 

Z Z O 4-1 

•H 

4-1 • • >^ (-1 

0) XI iH I-I U 

S < PQ Q 



bO 






C 


>. 




•H 


t-l 




c 


•1-1 




c 


to 




3 


•o 




I-I 


3 




>. 


to 




to 


0) 




1 


s 




1 

o 


IM 




ro 


o 


s 


€ 


(U 


o 


3 


MH 


•9 


CO 
I-I 


<4-l 


c 


0) 


4-1 


•H 


> 


cu 


s 


to 


a 



rol 



oi 

H 
[d 



(l4 









X! 




n 




CO 


& 


1-1 


>^ 




a a 


1 


(U 


CO 1 


(U 


o CO 


to 


4-) C 


1 


x; o 


CO § 


> 


4-1 •H 


C -H 


tH i»-i 


o 


•H O 




4-1 •H 


(U 


O 4-1 


•H iH 


U-l U 


•H 


>-H 


3 


4-1 


ex 4J 


c 


(U <U 


a, 


4J 


4.) 


•H4J 


O 


01 < 


CXCrt 


(U 


•1-1 XI 


CO ex 


sa 


O 


4J to 


•H 


•1-1 


X 


O 


Q) 3 


o 


^^ 


to 


o 


x: -o 


3 


I-I 0) 


•H to 




1-1 


•H 


to 01 


" § 




a. CO 


O 


to |>4 


w 


T3iH 


> 


iH > 


•a 


o 


3 E 


4-1 0) 




C OJ 


O 


o. o 


•a 1-4 


I-I 


oj ex 


iH T3 




Opi 


I-I 


01 XI 


C to 


CO 


5-9 


iH •H 


d) 3 




O^ 


PM 


U CO 


to M 


TJ 


O <4-l 


O M 



<U 


3 




C 


o 

iH 




•3 


lU 




d) 






4J 


2 


(0 


3 


to 


IH 


ex 


dJ 


o 


o 


4J 


3 


u 


CO 


•1-1 



a 
u 

H 

u 

Cd 
H 
O 
03 

C^ 

CO 
Cd 
C/l 

< 



z 
o 
I-I 
H 

< 

o 

l-J 



M Z 

fc < 

Cd 

z 

Cd 

pa 







CO 






CJ 


^ 






s 


u 
o 




U3 


§ 


3 


s 


tn 


< 


I-I 


3 


M 


cu 


d) 


•H 


,-3 


CO 


4-1 


4J 


O 




CO 


3 


h4 


CO 


3 


o 


M 


CO 




CJ 


3 


<: 




v«^ 




n 


x; 




O 




o 


d) 


Z 


Q 


o 


^ 


^ 


Cd 


•rl 


to 




a< 


U 


4J 


CO 




^ 


3 
M 


M 


&5 







^ 




> 




M 




> 




Pii 




t3 


•a 


CO 


§ 


CO 


iH 


CO 


CO 


<: 


M 


PQ 






CO 


Q 


ex 


Cd 


ex 


CM 


•H 


I-I 


x: 


BH 


o 


H 




CO 







d) 


M 


CO 


x: 


0) 


^ 


u 


> 


o 




•1-1 


M 


3 


Cil 


H 


O 




^ 


to 


o 

4-1 


C3 


4-1 


c 


I-I 


CO 


(U 


S 


•H 
> 


i 


z 




u 


o 


O 


o 


s 


•H 


to 


^ 


Oi 


C/1 



iH 


rH 




n 


U 


. 


O. 


o 


<U 


(U 


Vi 


o 



C/3 



M 
^ 



o o o 
o o o 
o m LO 



o o o 
o o o 
o o o 






o o o 
o o o 
o o o 



to n) 



o o ;j 

2 Z O 



o 
o 
m 



o 
o 
O 



o 
o 
o 



to 
o 



3 < 



m 



Q 



o 

M 
H 
Oi 
M 
OS 
CJ 
CO 

u 
a 



U} </} (A (A 

o o o o 

X. ji x: x: 



u~i u-i in \o 

CM CM CM m 






Ul U) Ul 

o o o 

x: j: x; 



o 



g e 3 

O O M -H 
3 Z O 4J 

•H 

u • ' >, u 

s <: tf> Q 



u 

60 
C P^ 

•H iH 
C -H 

C rt 
3 X) 

>> ^ 
CO 0) 

-a e 

00 M-l 
CM O 



.a 



60 
CO 

a) 



vol 
w 

0) 



§ 



to c 
dj -i-i 

•H ^ 

i-l to 

ex 4-1 

a 

(0 0) 

(-1 
XI to 

to to 



•H c 



c 



to en 

3 






CO 

c 

(0 

e 

v^ 

u 

w 

tn 
o 



w 

to 

o 

J2 



u 

vJD O 

• u 
in 0- 

C 

01 (U 

-=! -S 
H > 



3 

■a 
m B 
x; 

a in 
to . 

CN 

C -H 
•H 

fU 
to JZ 

0) 4-1 
•H 

O (1) 
C to 
0) 



o 



S 4-1 

^1 u 

(U tu 

4-1 jr 14-1 

OJ 4J 14-1 

a o tu 





.-H 




•H 


>. 


^1 


to to 


o. to 


S 14-1 


< 14-1 


1 CI 


1 O 


>^ 


>% 


u o 


u o 


to o 


to o 


3 O 


3 O 


M ' 


Vj « 


XI O 


X3 O 


(U iH 


01 t— 1 


pL, 


d- 



4J 

tu 

3 



to 4-1 

S rH 

C tu 

o g 

c ? 

XI o 

3 C 



o 

>4-l 

•H (U 
to T) 

■a c 

•H 

tu 
x: 3 

4J o 
tH 

14-1 l4-( 

4-1 

3 

01 O 
60 

to (0 
U 4-1 
Q) iH 



4J O 

o x: 

C to 

" to 

x: tu 

u 3 

C -H 

O to 

e > 

CO X 

0) 4-1 



■H 




•H 




)-l 


to 


0.14-41 


< 

1 


" 


>^0l 


Vj 


o 


to 


o 


3 




C 


CN 


to 


.H 


►-) 





o 

< 

H 
l-i 
CQ 

M 

a: 

X 

u 






o o 

z z 



< PQ 



o 

to vO 



(U O 



to 

to 
>^ X -a 

•H XI 

to C 

X) -H 



<U 
> X3 



•H 

2 



O 

4J -H 

3 Vj 

O (U 

<U D. 

to 

a 01 

o x: 



a; 
w 

H 

w 



CO 


4-1 


O 


•H 


•H 


> 


H 


•H 


4-1 


4-1 


o 


O 


OJ 


3 


rH 


X) 


u 


C 




o 




o 



s 




o 


to 


1-1 


14-1 


<4-l 


o 


4J 




s 


5 


CO 


X 


4J 


tu 


rH 


XJ 



Si5 



a 



Q 
U 

O 

Cd 

EH 

O 

w 



Z 

o 

M 
H 
-< 
U 

o 



u 

M 
PQ 



W 
M 

o 

l-H 

Q 



5C 
(/3 



fe 



01 >-l 

x: 0) 

4J > 

•H 

o 



u C 

to 0) 

•H a 

> 



O T3 
0) 



O O 

•H CO O 



§ 






60 

4-1 C 
to -H 

X) C 

c to 

to hJ 

r-l 

to >^ 

M 1-4 

u 

to 01 
O. fn 

o. 

x: -^ 
o o 



(0 

I-l 

CO 

p. 






PL, 

H 



2 
O 
M 
H 
CU 
M 

to 
u 

o 



CO 

cfl 

o 





^-v 


cu 


4) 










to 


rH 


Ql, 






T) 


13 


MX 




iH 




4J 


4-1 


<-^ 


s 






0) 


M 


to 


4-> 


C 


O 




3 


CO 


•H 


u 






M (-1 


CO 


^ 




•H 


t-i 


1 


O 0) 


CO 


> 








(U -H 


-a 


o 


OJ 




4J 


c 


X 


X 


O 


X) 


0) 


U 


4-1 D 


c 


4-1 


> 


rH 


C 


cu 


O 4J 


CO 


U 


s 


x; 


eu 


to a- 


CO 


CO 


o 


(U 


o 




& 




o 


4J 


> 


01 (U 


J-l 




X 


> 


o 


c 


4J UH 










•rl 


M M 


en 


U 


CO 


<U 




o 


o 


• • 


•» 


#t 


c 


pti 


60 




flj 




rH 


T3 


•H 


4-) 


60 


M 


M 


o 




W 


0) 


> 


i-i 




O 


4-1 


CO (U 


c 


•H 


•H 




^ 


U-i o 


> 


a) 


O 


g 


O 


CO 


cu 


•H 


O 


O 


<U 


•H C 


o 


C 




p 


iH 


e 


01 u 


S 


CO 


t 


60 


o 


>-• 


,Q 


(D 


4J 


.9 


MH 


ax 


o 


u 


to 


•H 


:5 


CO 


X 


CO 




eu 


O 4-1 


rH 


<u 


(U 


l-l 


U 


iH O 




S 




c 


CU 


CO 


iH 


r-i 


to 


CO 


o 


0) 


iH iH 


>> 




to 


•rH 


^ 


OJ 


(U Uh 


O 


0) 


^ 


4-1 


1 


< <+-l 


.£1 


1 


•H 


S 


4-1 


M 


> o 


C4H 


(S 


to 


1-1 


























O 


























U-l 


























>. 


CO 
























■H X 


CO 
























•ri (U 


0) 
























to TJ 


iH 


f^ 






















"O c 




3 






















•H 


JJ 


O 






















(U 


o 


X 






















x; s 


c 


Ifl 






















u o 


























rH 


n 


to 






















m in 


x: 


Q) 






















O 4J 


■w 


3 






















3 


C 


H 






















OJ o 


o 


CO 






















00 


B 


> 






















n) CO 


























^^ 4.) 


XI 


C 






















QJ rH 


o 


CO 






















> <u 


CO 


J2 






















< Q 


0) 


4J 























o 
o 

v£3 



O 
HO 
CO 



o 
o 
o 

en 



o 
>Jo 

to 

s 



CO 
CO 
vO 



•H 
U 



o 

lO 

< 

H 
H 
« 
M 

X 
Ed 





















to 




c 


























Vj 


4-1 




CO 


























<u 


,-i 


X 


X 


























> 


!U 


<D 


4-) 


























eu 


o 


•a 




























C 




c 


>-l 


CO 
























eu 


>> 


•H 


eu 


■4-1 
























x: 


l-H 




4-1 


o 
























S 


•H 

to 


3 

o 


to 
eu 


o 




















."^ 




1 


•a 


i-H 


u 


o 




















fu 








14-< 


OOO 








t-t 








rH 




> 




i-{ 


a; 


4-1 




«s 








rH 


-'-s 






rH 




ej 




rH 


XI 


3 


to 


CM 








<1 








< 




4-1 
O 

eu 




<i3 


4J 


O 

c 


•H 
1 


rH 


4J 


CN 




1 >. 


4-1 




c 


1 


>. 


•r-i "O 






o 


CO 


3 




eu 


rH 




U X 


O 




3 


u 


X 


O OJ 




to 


4-1 


X 


O 




e 






<u 


(U 




o 


eu 




V-i eu 




to 




4-1 


cu 


1 


4-1 


3 




> CO 


•I-) 




X 


> 


to 


PU O 




o 


a 




CO 


to 


Vj 


O 




•H 4-1 


o 


o 


to 


•H 


4-1 


X 




M 


3 


eu 


c 


•H 


to 


o. 




T) rH 


M 


4J 




TJ 


rH 


>^ eu 




a 




U 


o 


T3 


(X 


3 




Si 


PL, 




CO 




eu 


0) 


« 




U 


o 


o 




(U 






>%Q 




4J 


3i 


P^Q 


rH o 


r; 


to 


o 


e 




(U 


Q 


eu 




rH 


M 


o 


3 


rH 




<-i u 


3 


4J 


HH 




u 


X 








X (U 


(U 


c 


rH 


X 


eu 


CO 


O 


r-t 




O 


3 


4J 


eu 


w 




4J X 


4J 




to 


4J 


X 


> 4J 


XI 


eu 


to 


c 


o 




X 


O 


, 


S ^ 


5 


/^N 


> 


c 


4J 


o 


to 


Q 


eu 




>+H 


4-1 


4-1 




eu 


o 


13 


4J 




o 




■H n 






4J 


4-1 




CO 




T) 


u 


s g 




c 


eu 


a 


g 


CO 


to 


lU 


CO 


3 


14H 




>4-l 


C 


•H 


o 


eu 


eu 


X 




o 


u - 


0) 


O 


60X 


O 


to 


o 


to 


4-1 


TO <4H 


4J 


S 


4-1 


c 


^4 


w ^-N 


3 










>, 






O 


CO 


4J 




to 


<4H 


d 3 


r-i 


eu 


T-{ 


to 


4-1 


CO 


c 


X 


c 


a) 


4J 


U 


■a 


eu 




a> CO 


CO 


U 


eu 


>> 


3 


TJ 


o 


to 




S CO 


M 


to 


eu 


a 


to 


(-3 eu 


> 


3 


C 


CO 


O 




•rH 


•H 


to 


g 




D. 


eu 




c 


i-i 




to 


U 


-a 




0) 


4-1 


fa 


u 


(U o 


<u 


eu 


o 


eu 


o 


eu 3 


eu 


o 




O 


> 


eu 




3 


J3 -H 


x: 


Q 


X 


XI 


•H 


X M 


s: 


rH 


x: 


o 


s 


•H 


u 


14-1 


o 


H CO 


u 


N— ' 


eu 


H 


to 


4J ^-' 


4J 


a 


a 


CM 


4J 


4-1 


o 


o 


XI 



H 



PLI 



> 




o 


to 


l-t 


tJH 


UH 


o 


4J 




3 


c 


O 


•H 


to 


X 


4-1 


0) 


rH 


T3 


0) 


3 


p 


M 



I» to 

M MH 

OJ U 
> 

•■-I 3 

a -rt 



o 
w 

H 

u 

w 

H 

o 

PL4 
CO 

en 



2 

o 

M 
H 

<: 

CJ 

o 

l-J 



u 

M 

fa 
u 

w 



w 








fa 








M 




•3 




hJ 




3 




a 




CO 


•-N 


hJ 


ffi 


f-\ 


X) 


M 


to 


CO 


eu 


3 


^ 


M 


3 

c 


Q 


^ 


CO 


•rl 




g 


a. 

•H 


4J 


P3 


CO 


X 


o 


CO 


I-H 


u 




(-H 

fa 


^ 







I-H 


c 


CO 


^ 


o 

•H 


CO 
CO 


H 


CO 


X 


CO 


M 


CO 


p^ 


eu 


•O 4J 


o 


> 


eu rH 


U 


•H 


a. 01 




•3 


•H Q 


^ 


eu 


V4 

4-) cu 


ja 


N 


CO X 


o 


•H 


4-1 


M 


.^ 


60 

3 a 


« 


C 


3 O 


P^ 


•H 


o u 


Cd 


s 


>^>4H 


Oi 






o 







<4-l C 
O •H 



3 


to 


O 


CO 


•H 


CO 


CO 


X 


u 




eu 


13 CO 


> 


eu 4-1 


•H 


Cl.r-{ 


T3 


•H eu 




S-i Q 


eu 


4J 


t^ 


to rH 


•H 


to 


.a 


60 U 


3 4J 


3 


3 3 


•iH 


o eu 


S 


>^u 



hJ 

^ 






O 



u 

td 

a 



H 



Fi< 



u 

EH 

o 



CO 

u 

C3 



Pi4 






M 

Q 



ad 





m 






■o 






tn 
































.H 












(U 




<u 


























rH 






•H 




>^ 


4J 




V4 










•o 
















•H 






t-i 




XI 


•H 




Id 










s 
















W 






4-1 






rH 












c 
















D. 






tn 




u 


•H 




on 






>> 


o 


rH 






^ 










< 






M 




CO 

tu 


o 

to 




s 






rH 
rH 


•H 

to 


rH to 
CO 4-1 






Q 


u 
o 








iH 






C 




>%'+-i 




rH 






CO 


■H 


X CJ 








>4H 














3 


x; 








Cd 






00 


> 


CO CO 






a 










• 






O 


00 


QJ 


4-1 




> 






(U 


•H 


U 






5 


U 








§ 






>^ 


3 


X 


o 










rH 


Q 


4-1 4-1 






u 


c 














O 


4-1 


(U 




>. 










c c 






14-1 


OJ 








*-i 






4-4 


)-i 




•I-) 




fH 






to 


4-1 


QJ o 








g 














o 


x: 


00 


o 




•H 






•H 


c 


S tj . 






13 
















4.1 


c 


u 




CS 








to 


4-1 I-l 






0) 


■H 














p 




•iH 


eu 




•o 






3 


•H 


I-l >. CO 






I-l 


4-1 














o 


«v 


M 












to 


I-l 


CO rH tu 






QJ 


•H 














•H 


rH 


3 


M 




§ 






(U 


b 


a cu >> 






13 


4-1 














to 


iH 


•a 


(U 








)-l 




QJ (2. 






V^i 


c 














V-i 


•H 




4-) 




tu 




• 


3 


(U 


P 3 rH 






O 


OJ 














(U 


3 


tn 


to 




a 




rH 


CQ 


X 


tn CO 






















> 




c 


13 












4-1 


QJ O 






M 


rH 














•H 


Q) 


o 






iH 




rH 


tu 




X I-l -r-t 






QJ 


to 














-a 


4-1 

to 


•H 

4-1 


<u 

4-1 




rH 

to 




•H 
U 


X 

4-1 


OO 

c 


4J QJ 4-1 
4-1 -H 






4-1 

£5 


3 














QJ 


4-1 


a 


to 








D. 




•H 


14-1 CO I-l 






3 


C 








T-i 






^a 


Vi 


3 


4-1 




^ 




<: 


u 


"O 


o 3 CJ 








to 








^ 






•H 




T3 


t/1 




3 






tu 


3 








rH 














.n 


OJ 


tu 






O 




c 


4-1 


rH 


CO 14-1 I-l 






to 


QJ 














x; 


>-4 


X 




iH 




o 


2 


O 


01 o o 






c 


4-1 














c 


4J 




oo 




HH 






3 


x 


•H 






o 


to 














•H 




X 


3 








tn 




tu 


.H to >, 






•H 


.n 










«J 




s 


«t 


O 


o 




!-i 




C 


>» 




CU W I-l 






4-1 








I-t 


4J 






tn 


3 


u 




O 




•H 


§ 


A 


p. C 13 






•H 


4J 








<u 


iH 


U 


o 


4-1 


to 


X 




14-1 




00 


c 


3 QJ 






•a 


rH 








c 


(U 


4J 


u 




4-1 








tu 




o 


CO g iJ 






13 


3 








c 


Q 


X. 




o 


O 






4J 




XI 


<u 


•H 


QJ CO 






to 










CO 




u 


4J 


D< 


4-1 


1-4 




O. 






X 


4J 


a --I X 

C 4J 4J 








0) 








J= 


>. 




O 


X 




tu 




tu 




c 




CO 






to 


X 








u 


•H 


0) 




tu 


to 


4-1 

to 




o 
X 






iH 
rH 


3 


•H -H 

P^ 4-1 C 






3 
iH 


4-1 








to 


to 


4J 


o 


4-1 


3 


3 


• 


M 




.H 


CO 


13 


C -H 






D. 13 








to 


xl 


(0 


I-I 


a 


cr 




-a 




• 


o 


X 




CU 








QJ 








o 




0) 


PLI 


tu 


tu 


4-1 


fH 




tu 


o 


CO 


(U 


13 






rv^ 


QJ 








u 


0) 


^ 




•r-) 




o 


tu 


• 


> 






V4 


to < QJ 






§ 


O 








o 


x: 


60 


>^ 


O 


4-1 


tu 


•H 


to 


•H 


tn 


3 


O 


QJ to 






Q 


X 










w 




<u 


M 


c 


•r-) 


>> 


4-1 


CO 


•H 


CO 


a 


•I-t QJ O 


• 






OJ 








nJ 




tn 


r-i 


(X, 


3 


o 




c 


3 


X 


tu 




O .H O- 


I-l 




13 










4-1 


u 


•H 


r-\ 




o 


M 


4-1 


tu 


rH 


4-1 


U 


u 


c X a 

QJ to -H 


to 




§ 


iJ 








r-) 


(U 




to 


>^ 


a 


Cm 


u 


a 


O 




3 


o 


01 




o 








5 


> 


X 


> 


d) 


to 




tu 


S 


•S 


C 


PP 




•H H 


>» 






a 








O 


(U 


(U 




i-t 




>> 


•r-) 


M 


•i-l 




to 


O c 






OS 












c 


13 --N 


1-4 


■H 


c 


<u 


o 


3 






tu 


I-l 


•H I-l QJ 


rH 




EQ 


to 








l4^ 


0) 


C tn 


CO 


to 


to 


i-H 


M 


to 


tu 


4-1 


x: 


CO 


t4H QJ 0) 


to 




Crt 


QJ 








O 


-g 


•H 4-( 


U 


> 




nH 


PM 


CO 


W 


•H 


4J 


tu 


QJ 13 X 






P 


O 










3 


O 


■u 




tn 


to 




tu 


to 


.a 




>^ -a c 






13 








a; 


V— ^ 


3 


CI 


<-i 


tu 


> 


u 


a 




I4H 




:3 4-1 


O 




M 










M 




o o 


QJ 


to 


4-1 




tu 




to 


iH 


O 


o 


n o 


c 




O 


X 








3 


en 


■H O 


O 


^1 


to 


rH 


4-1 


tu 


(U 






rH 


to 13 C 






IH 


o 








M 


0) 


14-1 O 




4-1 


ij 


to 


to 


c 


4-1 


CJ 


to 




OJ QJ 


3 






•iH 








o 


4.) 


U - 


(U 


c 


Crt 


u 


s 


o 


to 


W 


(U 


14H 


>. M tn 


o 




to 


•§ 








iH 


<o 


3 tN 


x: 


tu 




4-1 




tvl 


T3 




•H 


o 


QJ QJ 


.H 




OJ 








U 


bO 


O rH 


4J 


u 


•a 


c 


<u 






^ 


rH 




rH > -H 


OJ 




•H 




















(U 


r<y 


4-1 


tu 


rH 


3 


O. 


4-1 


to -H O 


X 




iH 


t3 














f3 


tu 


4-1 


u 


CO 


a 


.-! 


3 


P. 


a 


O rH C 




• 


a 


§ 














o 


CJ 


•H 




4-1 


CO 


<: 


rH 


3 


CO 


•H 0) QJ 


U 


u 


p. 
















3 


C 


•a 


w 


>*-i 




o 


to 


I-l 


4-1 13 -H 


O 


to 


3 
















tn 


T3 


P 


tu 




u 




CJ 




4-1 


•H O 




QJ 


to 


M 














4-) 


0) 




u 


0) 


3 


• 




e 


c 


H OJ -H 


rH 


>. 




^ 














c 


Vj 


0) 


o 


o 


to 


to 


u 


o 


O > 14-1 


to 




a 


QJ 














•H 




X 


4J 


3 




4J 


c 


•H 


o 


to Q) 


g 


rH 


X 














to 


tu 


4-1 


to 


13 


u 


c 


(U 


U-l 




13 X 13 


to 


•H 


a 














U 


a 






tu 


o 


(U 


o 




CLj 


CO 'O 'O 


O 


O 


IM 


OJ 




• 










4J 


3 


t-l 


•4-1 


u 


14H 


a 


to 


C 


S 


c 


•rH 




4-1 




o 










tn 


■-n 


o 


o 






tu 


•r-i 


o 


o 


rH to 




4J 


4) 


D. 




o 










c 




U-l 




4-1 


Q) 


Vj 


•a 


■H 




>% 3 X 


QJ 


■rH 


X 


OJ 




m 










o 


T3 




c 


» 


u 


3 


CO 


to 


>-. 


M O 


> 


u 


rH 


Crt 




(M 










o 


S 


4J 


o 


c 


to 


to 




•rl 


c 


•O 3 to 


O 


o 


















M 


■H 


o 




to 


tu 


> 


CO 


4-1 


X 




^ 


to 




u 










iH 




O 


tn 


13 


to 


<u 


X 


o 




O iJ c 


to 


u 


J^ 


3 




CO 










to 


>. 


Du 


u 




tu 


a 


4-1 


>-l 


u 


4-1 C 0) 




o 


to 


o 














C 


CO 


to 


(U 


to 


3 






a, 


<u 


QJ a 


•% 






•H 




1 




t 






O 


S 


% 


> 


g 


tH 


>. 


•S 




13 


>. e QJ 


u 


>. 


CO 


> 






(U 






•H 




•H 


o 


to 


r-H 


to 


c 


rH 4J rH 


QJ 


I-l 


QJ 


QJ 






•K 


> 






4J 


M 


u 


TJ 


•H 


> 


U 




•H 


3 


C ^-1 4-1 


3 


13 


•H 


^ 




CO 




o 






to 


C 


u 


(U 


to 




3 


p 


X 




O to 4-1 






rH 


O. 




o 




S 






M 


•H 




^1 


u 


rH 


O 


3 


u 


U 


D. 0) 


to 


to 


a 






X 


CO 








0) 


U 


•» 




tu 


.H 


X 


o 




01 


4-1 QJ to 






cx 


QJ 






F-j 


rt 






a. 


3 


tn 


>^ 


> 


to 




X 


U-l 


> 


O Q 


00 


00 


3 


X 




a 


^ 


4J 






o 


t3 


C 


X 


•H 




4-1 


tn 


o 


•H 


QJ 4J 


c 


C 


tn 


4-1 






•"* 


i-i 










o 




T3 


«> 


to 






rH 


■n QJ X 


•H 


■H 






. 


QJ 


^ 


^ 






•u 


to 


•H 


u 




3 


to 


tn 


(U 


tu 


X X 00 


3 


3 


I-l 


I-l 


;-l 


^1 


Q 






to 


4J 


4-1 


o 


4-1 


O 


0) 


■H 


to 


•a 


3 4-1 -H 


o 


o 


QJ 


O 


o 


to 


?:^ 








X 


iH 


CO 




to 


nH 


iH 




o 




to yi 


.H 


iH 


4-1 


4-1 


4-1 




C/3 


en 


g 




4-1 


iJ 


U 


a 


X 


>4H 




(U 


a 


o 


n 


rH 


rH 


to 


O 


tj 


CO 


5 


w 


o 






Q 


(U 


o 


U 




4-1 


4J 


u 


4J 


•> 0) I-l 


o 


O 


3 


to 


to 


QJ 


O 


o 


^ 




4J 




(X 


■H 




)-l 


CO 


CO 


3 




C^ 4-1 O 


14H 


14H 




u 


u 


3 


o 


M 




c 


<U 


o 


tn 


to 


o 




-a 


fi13 


> to -H 






•a 


u 


4-1 


rH 




o 


n) 




0) 


X 




u 


tu 


>4H 


c 






(U 


CJ 3 I-l 


I-l 


u 


01 


c 


c 


CO 


^ 




C/3 




4-J 


4J 


13 


tu 


a 




O 


o 


(U 


4J 


D. 


to 


to 


rH 


o 


o 


> 


<u 






X 




(U 


> 


•H 


4J 




c 


X 


to 


QJ >< 


QJ 


QJ 


3 


o 


u 




g 


N 


M-l 




<u 





4-1 


•H 


4J 


I/) 


ax) 




4-1 


00 X (3 I-l 


>> 


P^Tl 






o 


o 


•H 


o 






O 


to 


■o 




w 


tu 


tu 


c 




•H 


4-1 CO 4) 






tu 


to 


13 


u 


M 


s 






<u 


U 


C 




X 


s 


o 


tn 


<u 


I-l 


rH 


13 


>^ 


>>x 




•H 




tj 


•rl 


iJ 




JS 


t4-l 


•H 


4-1 


O 


><; 


to 




o 


X 


14-1 Q) C 


U 


I-l 


O 


?>^ 


to 




•^ 


c 


c 




4-1 




TJ 


o 


3 


z 


w 


X 


5 


Pm 


O 


O X 3 


Q 


Q 


CO 


X 


to 


,, 


M 


•H 


(U 




o 


to 
tn 


^4 
O 


tu 

V4 


to 


g 


























£t; 








E-i 


CO 


o 


•H 


4J 


o 


-. 




— ^ 


-s.^ 









^^ 


■v^ 






o 








* 


XI 


u 


•o 


to 


b 


-Hi 




CNl 


t^l 






^1 


tn 


^1 






z 



o 



< 

H 
M 
M 
M 
DC 
X 
U 



YEAR CLASSIFICATION 



YEAR TYPEI^ 



Year classification shall be determined by the forecast 
of Sacramento Valley unimpaired runoff for the current water 
year (October 1 oi the preceding calendar year through 
September 30 o1 the current calendar year) as published in 
California Department of Water Resources Bulletin 120 for 
the sum of the following locations: Sacramento River above 
Bend Bridge, near Red Bluff; Feather River, total inflow to 
Oroville Reservoir; Yuba River at Smartville; American 
River, total inflow to Folsom Reservoir. Preliminary 
determinations of year classification shall be made in 
February, March and April with final determination in May. 
These preliminary determinations shall be based on hydro- 
logic conditions to date plus forecasts of future runoff 
assuming normal precipitation for the remainder of the 
water year. 



YEAR TYPE 

Wet \y 

Above Normal 1/ 
Below Normal 1/ 
Dry 

Critical 



RUNOFF, MILLIONS OF ACRE-FEET 

equal to or greater than 19.6 (except 
equal to or greater than 22.5 in a year 
following a critical year). ^ 
greater than 15.7 and less than 19.6 
{except greater than 15.7 and less than 
22.5 in a year following a critical year).?/ 
equal to or less than 15.7 and greater 
than 12.5 (except in a year following a 
critical year).?/ 

equal to or less than 12.5 and greater 
than 10.2 (except equal to or less than 
15.7 and greater than 12.5 in a year 
following a critical year).^ 

equal to or less than 10.2 (except equal 
to or less than 12.5 in a year following 
a critical year).?/ 



All Years for 
All Standards 
Except- 



■Year Following 
Critical Year 3/ 



19.6 



15.7 



12.5 



« 
«> 
U. 

O 



e 
o 



o 

a 
Oc 

(5 

E 



22.5 



10.2 



15.7 



12.5 



!/ 



?/ 



Any otherwise wet, above normal, or below noimal year may be designated a subnormal 
snowmelt year whenever the forecast ol April through July unimpaired runoff reported in 
the May issue oi Bulletin 120 is less than 5.9 million acre-feet. 

The year type lor the preceding water year will remain in effect until the initial forecast 
of unimpaired runoff for the current water year is available. 

'■Year following critical year" classification does not apply to Agricultural. Municipal and 
Industrial standards. 



Exhibit A 



7 of 7 



EXHIBIT B-1 



CENTRAL VALLEY 


PROJECT AND 


STATE WATER PROJECT ANNUAL 


SUPPLIES 


(all 


figures are 


in thousands of acre-feet) 




Central Valley Project 


State Water Proiect 


Total 


SACRAMENTO BASIN USE 








Sacramento River 




Feather River 




below Shasta 


2,954 


below Oroville 993 




American River Basin 


200 






Subtotal 


3,154 


993 


4,147 


EXPORT 









Tracy Pumping Plant 

Contra Costa 
Pumping Plant 

Cross Valley Canal 

Incremental Supply 



3,113 

90 
128 
432 



Delta Pxmiplng 

Plant 2,674 



Subtotal 3,762 

DELTA AREA AND OUTFLOW (JOINT RESPONSIBILITY) 



2,674 



6,436 
4.986 
15,569 



TOTAL 

Notes: (1) Annual supplies are based on operation study USCAL-2-82. 
(1928-1934 critical period) 

(2) Annual supplies in some cases include both water right 
entitlements and project supplemental water. 

(3) The listing of annual supplies by service areas is not 
intended to restrict the place of use of either party. 

(4) Cross Valley Canal supply relies on transport through 
State Water Project facilities. 

(5) Incremental supply is developed from remaining storage in 
Central Valley Project reservoirs at the end of the 
1928-1931 critical period and could be made available in 
the Delta on a firm basis with allowable (25%) deficiencies 
in critical years. It would require transport through 
State Water Project facilities. 

B-1 



EXHIBIT B-2 



CENTRAL VALLEY PROJECT AND STATE WATER PROJECT FULL DEVELOPMENT ANNUAL SUPPLIES 



(all figures are in thousands of acre-feet) 



Central Valley Project 

SACRAMENTO BASIN USE 

Sacramento River 
below Shata 

American River Basin 

Subtotal 

EXPORT 



Tracy Pumping Plant 

Contra Costa 
Pumping Plant 

Cross Valley Canal 

Incremental Supply 



3,264 

195 
128 
154 



State Water Project 



3,381 
1,132 


Feather River 
below Oroville 


1,031 


4,513 


1,031 



Delta Pumping 

Plant 2,059 



Total 



5,544 



Subtotal 3,741 

DELTA AREA AND OUTFLOW (JOINT RESPONSIBILITY) 



Notes: 



TOTAL 



2,059 



5,800 

4,918 

16,262 



(1) Figures are illustrative of annual supplies obtainable under the 
assumptions of operation study USCAL-3-82. (1928-1934 critical 
period) which assumes full development with exisitng facilities. 

(2) Annual supplies in some cases include both water right 
entitlements and project supplemental water. 

(3) The listing of annual supplies by service areas is not 
intended to restrict the place of use of either party. 

(4) Cross Valley Canal supply relies on transport through 
State Water Project facilities. 

(5) Incremental supply is developed from remaining storage in Central Valley 
Project reservoirs at the end of the 1928-1934 critical period and 
could be made available in the Delta on a firm basis with allowable 
(25%) deficiencies in critical years. It would require transport 
through State Water Project facilities. 

(6) American River Basin Supply includes 120 thousand acre-feet for Placer 
County Water Agency water rights. It is assumed delivered above Folsom. 



B-2 



EXHIBIT C 





♦Station 


No. 


Identifier Code 


1 


RSAN032 


2 


CHCCC06 


3 


CHWSTO 


4 


RSMKL08 


5 


SLCCH16 


6 


RSAC075 


7 


RSAN007 


8 


RSANOIB 


9 


RSAC092 


10 


CHDMC006 


11 


RSAClOl 


12 


RSAC139 


13 


R0LD14 


14 


RSAC081 


15 


RSAN112 


16 


B9D801.9 143.2 


17 


**D29 


18 


B9D802.0 137.2 



MONITORING LOCATIONS 



State Location 



San Joaquin River at San Andreas Landing 

Contra Costa Canal at P.P. #1 

West Canal at mouth/intake to CCFB 

Mokelumne River at Terminous 

Cache Slough at City of Vallejo intake 

Sacramento River at Chipps Island (Mallard Slough) 

Jan Joaquin River at Antioch 

San Joaquin iliver at Jersey Point 

Sacramento River at Enmaton 

Delta Mendota Canal 

Sacramento River at Rio Vista 

Sacramento River at Greens Landing 

Old River at Holland Tract 

Sacramento River at Collinsville 

San Joaquin River at Vemalis 

San Joaquin River at Blind Point 

San Joaquin River at Prisoners Point 

Piper Slough at Bethel Island 



Unless otherwise agreed, a continuous electrical conductivity (EC) recorder 
shall be maintained at all of the sites listed above except for the San Joaquin 
River at Prisoners Point (D29) where only a weekly EC measurement is required 
between April 1 and May 5 of each year, 

♦Station Identifier Code used in the Environmental Protection Agency STORET data base. 
**Bureau of Reclamation station identifier code. STORET code not available. 



Exhibit D 

Exchange Procedure to Provide D-1485 Condition 3 

Replacement Water (Article 10b of COA) 

The California State Water Resources Control Board (SWRCB) Decision 1485 

(D-1485) restricts exports from the Delta by the Central Valley Project 

(CVP) and the State Water Project (SWP) during May and June of each year 

by limiting each project to a mean monthly export of 3,000 ft3/s. However, 

1 
Condition 3 of D-1485 allows the CVP to make up any deficiency caused by 

the limitation by exporting at SWP facilities (Condition 3 water). In an 
effort to minimize the impact of the limitation on CVP and SWP power opera- 
tions and unless otherwise agreed, this exchange procedure will be followed. 

During May and June of each year the CVP shall have the option to provide 
and the SWP will accept an amount of energy on a mutually agreed upon schedule 
sufficient to pump some or all Condition 3 water at H. 0. Banks Delta Pumping 
Plant (Banks). Operation under this procedure shall not cause export from the 
Delta in excess of that shown in Exhibit A. Any energy supplied by the CVP 
under this procedure will be used for pumping of SWP water at Banks and/or any 
joint CVP-SWP pumping facility during May and June. Such energy shall be 
converted to dollars at the then current value of SWP energy and credited to a 
CVP exchange account (account). During months other than May and June, the 
SWP shall pump Condition 3 water for the CVP utilizing the account to cover 



1 
To the extent that operational constraints on the Central Valley Project 
to minimize diversion of young striped bass from the Delta during May 
and June reduce project exports, permittee, the United States Bureau of 
Reclamation, shall be allowed through coordinated operations to make up 
such deficiencies during later period of the year by direct diversion or 
by rediversion of releases of stored water through State Water Project 
facilities . 



the cost of associated pumping energy at Banks at the then current value of 
energy to the SWP. For accounting purposes all Condition 3 water shall be 
deemed to have been pumped at Banks at a rate of 297 KWH/AJ". This rate is 
based on the rated efficiency of the pumping plant. Any change in the rated 
efficiency of the pumping plant will result in a correlative change in this 
KWH/AF rate at Banks. 

The CVP shall have the option to convey all Condition 3 water through SWP 
facilities during July and August. However, it is recognized that the 
value of energy is time dependent. Therefore, it is likely that the value of 
energy to pump an amount of water in May and June will be different than the 
value for pumping an equal amount of water at other times of the year. Prior 
to April 1 of each year operators of the SWP shall estimate the value of 
off-peak and on-peak energy for each week of the following twelve months. 
Prior to April 20 the CVP operators in coordination with the SWP operators 
shall determine how much CVP energy can be provided for SWP pumping during the 
May-June period. In the event that the account balance is insufficient to 
purchase the necessary energy for pumping all Condition 3 water, the CVP may 
provide and SWP will accept additional energy needed to effect full recovery 
of Condition 3 water. In the event that the entire quantity of Condition 3 
water is received by the CVP prior to the depletion of the account, the 
SWP shall credit the CVP with energy for additional pumping at Banks Pumping 
Plant or any joint CVP-SWP pumping facility until the account reaches a zero 
balance each year. 



EXHIBIT E 
WATER SHORTAGE AND APPORTIONMENT 
1. (a) In its operation of the Central Valley Project (CVP), the United 
States will use all reasonable means to guard against a condition of shortage 
in the quantity of water available to the State pursuant to this contract. 
Nevertheless, if a shortage does occur during any year because of drought, 
or other causes which, in the opinion of the Contracting Officer, are beyond 
the control of the United States, no liability shall accrue against the United 
States or any of its officers, agents, or employees for any damage, direct or 
indirect, arising therefrom. 

(b) In any year that the Contracting Officer determines there is 
a shortage in the quantity of water available to customers of the United 
States from the CVP, the Contracting Officer will apportion available water 
among the water users capable of receiving water from the same CVP facilities 
by reducing deliveries to all such water users by the same percentage, unless 
he is prohibited by existing contracts, CVP authorizatons, or he determines 
that some other method of apportionment is required to prevent undue hardship. 
In the event reduced deliveries are necessary, the water supplies for both 
municipal and industrial use, and agricultural use shall be reduced by the 
same percentage for each contractor. 

(c) If operation of the CVP to meet legally required Delta water 
quality control standards, including Federally adopted water quality standards, 
causes a shortage in water supply and requires a reduction in deliveries of 
water to the State under this agreement, such reductions will be made in 
accordance with subdivision (b) of this exhibit and shall not be deemed a 
breach hereof. 



STATEMENT OF THE 

CALIFORNIA DEPARTMENT OF WATER RESOURCES 

BEFORE THE 

U.S. HOUSE OF REPRESENTATIVES 

COMMITTEE ON INTERIOR AND INSULAR AFFAIRS 

SUBCOMMITTEE ON WATER AND POWER RESOURCES 

HONORABLE GEORGE MILLER, CHAIRMAN 

BY 

DAVID N. KENNEDY 
DIRECTOR 
DEPARTMENT OF WATER RESOURCES 

Mr. Chairman, members of the Committee, I would like to begin my 
testimony by thanking you for the interest you have shown in the 
Coordinated Operation Agreement and particularly for giving us the 
added impetus of this hearing to successfully conclude negotiations 
in Sacramento. 

Before I get into the agreement itself, I believe a little history 
might be helpful. The Department of Water Resources and the Bureau 
of Reclamation have operated their respective projects pursuant to a 
coordinated operations agreement since the first unit of the State 
Water Project, the South Bay Aqueduct, became operational in 1962. 
The agreement that is currently in effect was signed May 16, 1960. 
That agreement was designed (1) to provide a method of allocating 
shortages in water supplies by prorating the shortage on the basis 
of specified annual diversion amounts; (2) to resolve the protest of 
each party to the applications of the other for water rights 
consistent with these annual diversion amounts and (3) to clear the 
way for construction of San Luis Reservoir and related facilities. 

While the May 16, 19 60 agreement provided the basis for coordinated 
operations, it recognized in Article 16 that further agreement on 
additional and more specific criteria would be needed for actually 
operating the two projects on a truly coordinated basis. 

Negotiation of operating criteria started in 1961, and continued 
through May 13, 1971, when a draft agreement was completed. That 
draft agreement was never executed because of a stipulated judginent 
obtained in the lawsuit filed by the Environmental Defense Fund 
which prohibited approval of the agreement until an environmental 
impact statement had been prepared. However, the 1971 draft did 
provide an operating procedure for use by the operators of the CVP 
and SWP to determine proportionally how much water each project must 
supply from its reservoirs for uses in the Sacramento Valley, 



Presented May 23, 1985, in Washington, D.C. 



including the Delta, and how much water each project is entitled to 
export from the Delta. Through 1982, with the exception of 1976, 
the Department and Bureau operated the projects in a coordinated 
manner based on annual letters of agreement which essentially 
followed the terms of the 1971 agreement. 

Experience in operating and developing both projects particularly 
during the 76-77 drought, has shown that actual conditions are 
significantly different from what was assumed during the 
negotiations of the May 13, 1971, draft agreement. That agreement 
was negotiated using the November 19, 1965, Agreement on Delta Water 
Quality, which assumed a minimum outflow of about 1800 cfs from the 
Delta to San Francisco Bay. We now know higher minimum outflows are 
required. (Exhibit B of 1971 shows 2,911,000 acre feet per year for 
Delta area and outflow - Exhibit B-2 of 1985 shows 4,918,000 acre 
feet). In 1971, additional facilities were also assumed to be 
constructed such as a 2 million acre feet Auburn Reservoir, the 
Peripheral Canal and the Eastside Project of the CVP. Consequently, 
in 1979 negotiating teams of each agency were established to 
reevaluate the operating criteria, determine the proportionate water 
supplies available for each project, and develop a revised 
operations agreement. 

The negotiators initially considered using a procedure based upon 
the priority of water rights as modified by the 1960 agreement. 
However, such a procedure was quickly discarded as impractical. 
Instead, an equitable sharing of water supplies available to the 
projects was accomplished by a negotiated step-by-step procedure. 
This procedure met most CVP requirements before utilizing assumed 
water supplies for the SWP. It was not a determination as to the 
priority of the water rights between the two projects, but merely a 
useful mechanism for carrying out practical operations studies. 
Dams and pumping plants of the Federal CVP were given the first 
opportunity to use the available water supply and also the first 
responsibility to meet in-basin needs and assure Delta water quality 
in compliance with standards (Exhibit A of the Agreement) extracted 
from the State Water Resources Control Board Decision 14 85. 



first study included operation of the existing CVP system, 
. uding the San Luis Unit, and included all instream prior rigl 
environmental requirements. 



The second study added the SWP system and the federal San Luis Unit. 
The water supply available for this study was the excess Delta 
outflow from Study No. 1 and was shared 50/50 between the CVP and 
the SWP. This sharing was developed through negotiations. 

The results of these two studies are shown in Exhibit B of the 
Coordinated Operation Agreement. These two studies were prepared at 
both the current level of development and at the assumed "full" 
level of development (year 2020). 

The results of Study No. 2 for the current (1980) level of 
development were used to design a sharing formula. The resulting 



i 
I 



sharing formula provided for CVP/SWP proportionate split of 75/25 
responsibility for meeting in-basin use from stored water releases 
and 55/4 5 for capture of excess flow. The formula was arrived at by 
reasoning, trial and error, and negotiation. 

I would like to emphasize that the essence of the coordinated 
operations is the sharing formula, not the water supply figures in 
Exhibit B-1. The projects are not to be operated to meet 
predetermined yields but rather to first meet the needs in the areas 
of origin including the Delta water quality standards and flow 
requirements contained in Exhibit A; only then is water exported 
from the Delta. The COA does not affect the rights of third parties 
(Article 18) . 

After 25 formal negotiating sessions and innumerable meetings of 
subcommittees, agreement was once again reached by the negotiating 
teams in December 1982. Following changes in the management at the 
Department and Regional Office of the Bureau, negotiations were 
resumed in 1984 and eight formal sessions were held to address areas 
of concern, primarily in Articles 10 and 11. I will discuss these 
in some detail. All formal negotiating sessions were open and 
attended by representatives from various segments of the public. 
Agreement was reached by the negotiating teams at the May 6, 1985, 
meeting . 

The basic points included in the agreement are: 

1. Both parties agree to meet a specified set of water quality 
standards (Exhibit A) from State Water Resources Control Board 
Decision 1485. Article 11 also requires that Exhibit A shall be 
amended to include any new Delta standards that are not inconsistent 
with Congressional directives. However, if the Secretary of the 
Interior determines that new standards are inconsistent 
with Congressional directives, the Secretary is promptly to 
request the Department of Justice to bring an action to 
determin